Land Use & Air Quality Committee

Sacramento Area 1415 L Street, tel: 916.321.9000 Suite 300 fax: 916.321.9551 Council of Sacramento, CA tdd: 916.321.9550 Governments 95814 www.sacog.org

Thursday, August 2, 2012 at 1:00 p.m.

Roll Call: Directors Aguiar-Curry, Billeci, Griego, Jankovitz, McBride (non-voting), Montna, Payne, Scherer, West, Vice Chair MacGlashan, and Chair Cosgrove

Members of the public may comment on any item on the agenda at the time that it is taken up by the Board. We ask that members of the public come forward to be recognized by the Chair and keep their remarks brief.

1. Minutes of April 5, 2012 Meeting◄ 2. Public Release of Draft Regional Housing Needs Plan◄(Mr. Chew) 3. Update on MTP/SCS Implementation (Ms. Lizon) 4. Water Issues Update (Mr. Johnson) 5. Flood Issues Update (Mr. Johnson) 6. Regional Habitat Conservation Plans Update (Ms. McKinley) 7. Six-County Aquatic Resource Inventory Update (Ms. McKinley) 8. Other Matters 9. Adjournment ◄ Indicates Action Prepared by: Approved by:

Mike McKeever Tom Cosgrove Chief Executive Officer Chair

Next committee meeting: August 30, 2012

The Meridian Plaza Building is accessible to the disabled. If requested, this agenda, and documents in the agenda packet can be made available in appropriate alternative formats to persons with a disability, as required by Section 202 of the Americans with Disabilities Act of 1990 and the Federal Rules and Regulations adopted in implementation thereof. Persons seeking an alternative format should contact SACOG for further information. In addition, a person with a disability who requires a modification or accommodation, including auxiliary aids or services, in order to participate in a public meeting should contact SACOG by phone at 916-321-9000, e-mail ([email protected]) or in person as soon as possible and preferably at least 24 hours prior to the meeting. Parking is available at 15th and K Streets

Item #12-5-1 Land Use & Air Quality Committee Action

July 24, 2012

Minutes of April 5, 2012 Meeting

Issue: The Land Use & Air Quality Committee met on April 5, 2012.

Recommendation: Approve the minutes of the meeting as submitted.

Discussion: Attached are the minutes of the April 5, 2012 Land Use & Air Quality Committee meeting for approval.

Approved by:

Mike McKeever Chief Executive Officer

MM:RS:ef

Attachment

Key Staff: Rebecca Sloan, Director of External Affairs & Member Services, (916) 340-6224

S:\SACOG\Board\Land Use & Air Quality Committee\2012\8-August\1-Minutes.doc

SACRAMENTO AREA COUNCIL OF GOVERNMENTS LAND USE & AIR QUALITY COMMITTEE

DRAFT ACTION MINUTES

The SACOG Land Use & Air Quality Committee met on April 5, 2012 in the Sacramento & American Rivers rooms on the Third Floor of the Meridian Plaza Building located at 1415 L Street, Sacramento, CA at 1:00 p.m.

CALL TO ORDER: Chair Cosgrove called the meeting to order at 1:02 p.m.

ROLL CALL: Present: Directors Anderson, Billeci, Jankovitz, MacGlashan, Payne, and Chair Cosgrove

Absent: Directors Griego, McBride, Montna, and Scherer

1. Minutes of March 1, 2012 Meeting

Upon motion by Director Billeci, seconded by Director Jankovitz, and carried unanimously, the minutes of the March 1, 2012 Land Use & Air Quality Committee meeting were approved without any changes.

2. Public Release of Draft Regional Housing Needs Allocations

Upon motion by Director West, seconded by Director Billeci, and carried unanimously the Land Use & Air Quality Committee recommended that the SACOG Board of Directors release the associated allocations.

3. Metropolitan Transportation Plan/Sustainable Communities Strategy for 2035 Environmental Impact Report

The committee received and discussed this report.

4. Metropolitan Transportation Plan/Sustainable Communities Strategy for 2035

The committee received and discussed this report.

5. Draft Metropolitan Transportation Improvement Program Amendment #14 and the Draft Air Quality Conformity Analysis

The committee received and discussed this report.

6. Other Matters

Rebecca Sloan announced Senator Feinstein’s Luncheon to be held on April 10, 2012 at the Citizen Hotel at 11:00 a.m.

7. Adjournment

The meeting adjourned at 1:35 p.m.

Item #12-8-2 Land Use & Air Quality Committee Action

July 26, 2012

Public Release of Draft Regional Housing Needs Plan

Issue: Should SACOG publicly release the draft Regional Housing Needs Plan (RHNP)?

Recommendation: That the Land Use & Air Quality Committee recommend that the Board release the RHNP.

Discussion: SACOG is near the final steps in adopting its 2013-21 Regional Housing Needs Allocation (RHNA), a state requirement to determine the number of housing units cities and counties must plan for in their housing element updates. At its April 19 meeting, the SACOG Board of Directors approved the public release of the draft Regional Housing Needs Allocation (RHNA). The draft allocations were based on Methodology B, adopted by the SACOG Board at its December 15 meeting. Cities and counties were given 60 days, until June 18, to submit requests for revisions to the draft allocations.

No requests for revisions were received by SACOG, thereby closing the process by which the allocations can be altered. The final step in the RHNA process is to adopt the allocations in a plan document, referred to as the Regional Housing Needs Plan. Upon adoption of the RHNP by the SACOG Board and review and approval by the California Department of Housing and Community Development, the allocations take effect and the cities and counties must prepare and approve their housing element updates by October 31, 2013.

Attached is the draft RHNP. It includes background discussions on the state housing element law and RHNA, SB 375, the development and adoption of RHNA methodology, allocations and other relevant matters. If approved by the Board for public release, it is anticipated that the Board will adopt the document at its September 20 meeting.

For additional background information, visit the RHNA website at http://www.sacog.org/rhnp/rhna.cfm.

Approved by

Mike McKeever Chief Executive Officer

MM:GC:sb

Attachment

Key Staff: Gordon Garry, Director of Research and Analysis, (916) 340-6230 Rebecca Sloan, Director of External Affairs & Member Services, (916) 340-6224 Greg Chew, Senior Planner, (916) 340-6227 s:\sacog\board\land use & air quality committee\2012\8-august\2-rhnp_cover memo.doc 13-005-03 RHNP

REGIONAL HOUSING NEEDS PLAN 2013–2021

DRAFT AUGUST 2, 2012 BOARD MEMBERS AND MEMBER JURISDICTIONS SACOG MISSION Delivering transportation Peter Hill (Chair), City of Rocklin projects; providing public Mary Jane Griego (Vice Chair), Yuba County information and serving as a dynamic forum for regional John Allard, City of Roseville planning and collaboration Harold Anderson, City of Winters in the greater Sacramento Christina Billeci, City of Marysville Metropolitan Area David Sander, City of Rancho Cordova Christopher Cabaldon, City of West Sacramento Steve Cohn, City of Sacramento Tom Cosgrove, City of Lincoln Gary Davis, City of Elk Grove Carl Hagen, City of Placerville Kevin Hanley, City of Auburn Diane Hodges, City of Live Oak Jim Holmes, Placer County Robert Jankovitz, City of Isleton Kevin Johnson, City of Sacramento John Knight, El Dorado County Joe Krovoza, City of Davis Roberta MacGlashan, Sacramento County Leslie McBride, City of Yuba City Steve Miklos, City of Folsom Larry Montna, Sutter County Barbara Payne, City of Galt Susan Peters, Sacramento County Don Saylor, Yolo County Walt Scherer, Town of Loomis Phil Serna, Sacramento County Jeffrey Slowey, City of Citrus Heights Tom Stallard, City of Woodland Vacant, City of Colfax

Rick West, City of Wheatland 1415 L Street, Suite 300 Sacramento, CA 95814 Jody Jones (Ex-Officio Member),Caltrans District 3 tel 916.321.9000 tdd 916.321.9550 www.sacog.org WHAT WE DO EXECUTIVE STAFF The Sacramento Area Council of Governments (SACOG) is an Mike McKeever association of Sacramento Valley governments formed from the six Chief Executive Officer regional counties—El Dorado, Placer, Sacramento, Sutter, Yolo and Yuba—and 22 member cities. SACOG’s directors are chosen from Kirk Trost the elected boards of its member governments. SACOG’s primary Chief Operating Officer/ charge is to provide regional transportation planning and funding, General Counsel as well as a forum for the study and resolution of regional issues. In this role, SACOG prepares the region’s long-range transportation PROJECT STAFF plan; approves distribution of affordable housing around the region; keeps a region-wide database for its own and local agency use; Gordon Garry helps counties and cities use federal transportation funds in a Director of Research and Analysis timely way; assists in planning for transit, bicycle networks, clean Rebecca Sloan air and airport land uses; and has completed the Blueprint Project Director of External Affairs and which links transportation and land development more closely. Member Services Joe Concannon Data Services Manager This report was funded in part through grants from the Federal Highway Administration and Federal Transit Administration, Greg Chew U.S. Department of Transportation. The views and opinions of Senior Planner/Project Manager the authors or agency expressed herein do not necessarily state Kacey Lizon or reflect those of the U.S. Department of Transportation. Senior Planner Jennifer Hargrove Associate Planner Tina Glover Associate Research Analyst Erik Johnson Government and Media Affairs Coordinator

SACOG.ORG Sacramento Area Council of Governments

2013‐2021 REGIONAL HOUSING NEEDS PLAN

(Draft July 26, 2012)

CONTENTS

Executive Summary

Section I: Introduction

Section II: Growth Projections for the MTP/SCS and RHNA

Section III: RHNA Factors

Section IV: Adopted RHNA Methodology and Allocations

Section V: Comments/Questions Regarding Adopted Methodology

APPENDICES

1. Regional Housing Needs Determination Letter

2. Five Draft Methodologies:

A. Narrative Description of Draft Methodologies

B. Associated Allocations of Draft Methodologies

C. Comment Letters on Draft Methodologies

D. SACOG Response to Written Comments

3. California Government Code Section 65584

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 1 Regional Housing Needs Plan for the

SACOG Region

January 1, 2013 through October 31, 2021

(Draft July 26, 2012)

EXECUTIVE SUMMARY

The Regional Housing Needs Allocation (RHNA) establishes the total number of housing units that each city and county must plan for within an eight‐year planning period. Based on the adopted RHNA, each city and county must update the housing element of its general plan to demonstrate how the jurisdiction will meet the expected growth in housing need over this period of time.

This document, the Regional Housing Needs Plan (RHNP), officially assigns the allocations to cities and counties in the six‐county Sacramento region. This RHNP covers the planning period from January 1, 2013 to October 31, 2012. The allocation is based on the Sacramento Area Council of Governments (SACOG) region’s projected housing needs over the planning period.

The state‐mandated RHNA process (Government Code Sections 65580 et seq.) requires SACOG to develop a methodology that determines how to divide and allocate an overall allocation that the region receives from the state. The California Department of Housing and Community Development (HCD) determined that the total regional housing need in the SACOG area for this planning period is 104,970 housing units. The RHNA methodology distributed these units to each city and county within El Dorado, Placer, Sacramento, Sutter, Yolo, and Yuba counties, including the Tahoe Basin of El Dorado and Placer counties.

As the RHNP tables demonstrate, each jurisdiction received one “overall” allocation, which was then divided into four income categories of housing affordability. By distributing the overall allocation into four income categories, which are defined by state law, the methodology reduces the over‐concentration of lower income households in one community versus another.

There are two key components of the RHNP: (1) the RHNA methodology, and (2) the resulting allocation tables which indicate the projected new housing targets by income group, and the distribution of housing needs for each income group.

In developing the five alternative draft methodologies, SACOG staff consulted extensively with the Regional Planners Committee, comprised of planning staff from each of SACOG’s 28 member cities and counties. The public and advocacy groups also had the opportunity to comment on the methodology during the 60‐day public comment period. Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 2 The foundation for each jurisdiction’s overall allocation is the 2035 Metropolitan Transportation Plan (MTP) Update projections that SACOG developed in collaboration with each jurisdiction. The SACOG Board of Directors considered five methodologies to apply these projections. All the methodologies start each jurisdiction with a percentage of affordable units equal to the percentage of existing affordable income households in the region.

Methodology B, which was approved by SACOG’s Board of Directors on December 15, 2011, applies an adjustment factor to the base percentage based on regional income distribution disparities. Similar to the methodology used in the 2006‐2013 RHNA, the adjustment factor adds future affordable units to jurisdictions that currently have lower than the regional average and subtracts future affordable units from jurisdictions that have higher than the regional average. This methodology moves all jurisdictions towards the regional average, but rather than every jurisdiction achieving regional parity by 2050, each jurisdiction will reach the regional average at different points in time.

Following the Board’s approval of Methodology B, the housing unit allocations for each jurisdiction were calculated and released for public review, and the affected cities and counties were given the opportunity to request revisions to their allocation during a 60‐day period. No requests for revisions were received, thereby concluding the opportunities for jurisdictions to appeal the allocations to the SACOG Board of Directors.

By October 2013, each jurisdiction must update its housing element consistent with the 2013‐ 21 RHNA and submit it to HCD. The housing element must demonstrate that adequate sites and zoning are available to address anticipated housing demand during the planning period and that market forces will not inhibit addressing the housing needs of all economic segments of a community. HCD reviews each jurisdiction’s housing element update for compliance with state law.

Table 1 summarizes the overall allocation of units to each jurisdiction and the allocation by the four income categories.

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 3 Executive Summary: Table 1 ‐ Allocations ‐ Total and by Income Category SACOG 2013‐2021 RHNA ‐ FINAL ALLOCATIONS

Total Updated Projected Growth (Jan 1, 2013‐ October 31, 2021) Total number of Units (based Combined Low + Very on proportion of MTP/SCS Very Low Income Low Income Moderate Above Moderate Low Income 2020 projection) #%#%#% # % #% Placerville 372 78 21.0% 55 14.8% 69 18.5% 170 45.7% 133 35.8% South Lake Tahoe1 336 54 16.1% 38 11.3% 63 18.8% 181 53.9% 92 27.4% El Dorado Uninc Tahoe Basin1 480 132 27.5% 93 19.4% 89 18.5% 166 34.6% 225 46.9% El Dorado Uninc 3,948 954 24.2% 669 16.9% 734 18.6% 1,591 40.3% 1,623 41.1% El Dorado County total 5,136 1,218 23.7% 855 16.6% 955 18.6% 2,108 41.0% 2,073 40.4%

Auburn 308 74 24.0% 52 16.9% 57 18.5% 125 40.6% 126 40.9% Colfax 51 10 19.6% 7 13.7% 10 19.6% 24 47.1% 17 33.3% Lincoln 3,790 953 25.1% 668 17.6% 705 18.6% 1,464 38.6% 1,621 42.8% Loomis 154 39 25.3% 27 17.5% 29 18.8% 59 38.3% 66 42.9% Rocklin 3,813 1,040 27.3% 729 19.1% 709 18.6% 1,335 35.0% 1,769 46.4% Roseville 8,478 2,268 26.8% 1,590 18.8% 1,577 18.6% 3,043 35.9% 3,858 45.5% Placer Uninc Tahoe Basin1 328 90 27.4% 63 19.2% 61 18.6% 114 34.8% 153 46.6% Placer Uninc 4,703 1,275 27.1% 894 19.0% 875 18.6% 1,659 35.3% 2,169 46.1% Placer County total 21,625 5,749 26.6% 4,030 18.6% 4,023 18.6% 7,823 36.2% 9,779 45.2%

Citrus Heights 696 146 21.0% 102 14.7% 130 18.7% 318 45.7% 248 35.6% Elk Grove 7,402 2,035 27.5% 1,427 19.3% 1,377 18.6% 2,563 34.6% 3,462 46.8% Folsom 4,633 1,218 26.3% 854 18.4% 862 18.6% 1,699 36.7% 2,072 44.7% Galt 679 131 19.3% 91 13.4% 126 18.6% 331 48.7% 222 32.7% Isleton 23 4 17.4% 3 13.0% 4 17.4% 12 52.2% 7 30.4% Rancho Cordova 7,008 1,539 22.0% 1,079 15.4% 1,303 18.6% 3,087 44.0% 2,618 37.4% Sacramento 24,101 4,944 20.5% 3,467 14.4% 4,482 18.6% 11,208 46.5% 8,411 34.9% Sacramento Uninc 13,844 3,149 22.7% 2,208 15.9% 2,574 18.6% 5,913 42.7% 5,357 38.7% Sacramento County total 58,386 13,166 22.5% 9,231 15.8% 10,858 18.6% 25,131 43.0% 22,397 38.4%

Live Oak 449 104 23.2% 72 16.0% 83 18.5% 190 42.3% 176 39.2% Yuba City 2,679 624 23.3% 437 16.3% 498 18.6% 1,120 41.8% 1,061 39.6% Sutter Uninc 335 85 25.4% 60 17.9% 62 18.5% 128 38.2% 145 43.3% Sutter County total 3,463 813 23.5% 569 16.4% 643 18.6% 1,438 41.5% 1,382 39.9%

Davis 1,066 248 23.3% 174 16.3% 198 18.6% 446 41.8% 422 39.6% West Sacramento 5,977 1,316 22.0% 923 15.4% 1,111 18.6% 2,627 44.0% 2,239 37.5% Winters 319 76 23.8% 54 16.9% 59 18.5% 130 40.8% 130 40.8% Woodland 1,877 390 20.8% 274 14.6% 349 18.6% 864 46.0% 664 35.4% Yolo Uninc 1,890 427 22.6% 299 15.8% 351 18.6% 813 43.0% 726 38.4% Yolo County total 11,129 2,457 22.1% 1,724 15.5% 2,068 18.6% 4,880 43.8% 4,181 37.6%

Marysville 72 12 16.7% 8 11.1% 13 18.1% 39 54.2% 20 27.8% Wheatland 483 109 22.6% 76 15.7% 90 18.6% 208 43.1% 185 38.3% Yuba Uninc 4,676 1,036 22.2% 727 15.5% 870 18.6% 2,043 43.7% 1,763 37.7% Yuba County total 5,231 1,157 22.1% 811 15.5% 973 18.6% 2,290 43.8% 1,968 37.6%

SUM 104,970 24,560 23.4% 17,220 16.4% 19,520 18.6% 43,670 41.6% 41,780 39.8% Section I:

INTRODUCTION

This section provides background information about the Regional Housing Needs Allocation (RHNA) and the Regional Housing Needs Plan (RHNP) in the form of an FAQ.

What are the RHNA and RHNP?

The Regional Housing Needs Allocation (RHNA) establishes the total number of housing units that each city and county must plan for within an eight‐year planning period. Based on the adopted RHNA, each city and county must update its housing element to demonstrate how the jurisdiction will meet the expected growth in housing need over this period of time.

The RHNA and RHNP are part of the state‐mandated housing element law (Government Code Sections 65580 et seq.).

What are the objectives of the state housing element law?

The state housing element law (Government Code Section 65584 (d)) requires the RHNA to be consistent with four objectives:

1. Increasing the housing supply and the mix of housing types, tenure, and affordability in all cities and counties with the region in an equitable manner, which shall result in all jurisdictions 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, and the encouragement of efficient development patterns.

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

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 explained later, SACOG’s Metropolitan Transportation Plan and Sustainable Communities Strategy (MTP/SCS) and its RHNA are consistent with these objectives.

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 5 What was the process for developing the RHNA?

The State of California, through the Housing and Community Development Department (HCD), issued a Regional Housing Needs Determination to SACOG’s six‐county region for the January 1, 2013 to October 31, 2021 planning period (see appendix for the September 26, 2011 letter of determination). HCD calculated the regional determination using information provided by the California Department of Finance. The regional determination includes an overall housing need number, as well as a breakdown of the number of units required in four income distribution categories, as further defined below. The region’s overall allocation is 104,970 housing units.

Based on the regional determination provided by HCD, SACOG must develop the allocation of units to each jurisdiction, and the plan document that contains the allocations. The state‐ mandated RHNP allocates a projected share of the regional determination to each of the cities and counties in SACOG’s six‐county region. The RHNA establishes the total number of housing units that each city and county must plan for within the eight‐year planning period. Based on the adopted RHNA, each city and county must update its housing element to demonstrate how the jurisdiction will meet the expected growth.

What is SACOG’s role in the RHNA Process?

California’s Housing Element Law (Government Cod Sections 65580 et seq.) mandates that SACOG develop and approve a RHNA and RHNP for its six‐county region, including the counties of El Dorado, Placer, Sacramento, Sutter, Yolo, and Yuba, and their 22 cities. The RHNA and RHNP must also include the Tahoe Basin portions of El Dorado and Placer counties, and the city of South Lake Tahoe, which are not normally within SACOG’s planning area.

It is SACOG's responsibility to coordinate with HCD prior to its determination of the regional housing need. Once SACOG receives the regional determination, including the overall need number and the income category distribution, it must adopt a methodology for distributing the regional growth number throughout the region. The methodology is the basis for the final RHNA and RHNP that SACOG ultimately adopts.

What are the two types of allocations in the RHNA?

The RHNA has two parts as required by state law:

1. Overall Allocation: SACOG receives a total housing unit number for growth during the planning period in the six‐county SACOG region, including the Tahoe Regional Planning Area, from HCD. SACOG is required to distribute this regional housing growth number to the jurisdictions within the region for the period from January 1, 2013 to October 31, 2021.

2. Income Category Distributions: HCD also provides a household income distribution of the total regional housing unit number. As defined by state law, four income categories make up this distribution: very low income (less than 50 percent median family income

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 6 [MFI]); low income (50 to 80 percent MFI); moderate income (80 to 120 percent MFI); and above moderate income (above 120 percent MFI). The total housing unit growth SACOG allocates to each jurisdiction must be further allocated into the four household income categories.

What are the four income categories and what do they mean for cities and counties?

The four income categories, as listed above, must be addressed in a jurisdiction’s housing element. Specifically, accommodations must be made to ensure that the jurisdiction provides sufficient zoning capacity to accommodate the projected housing need in each income category. For the very low and low‐income categories, jurisdictions generally are required to identify sites (constructed or vacant) zoned at multifamily residential densities.

It is important to note that each jurisdiction is responsible for providing sufficient zoning capacity for the units allocated to all four economic income categories, but is NOT responsible for the construction of these units. The intent of the housing element law is to ensure that jurisdictions do not impede the construction of housing in any income category. Other factors, such as market forces, are well beyond a jurisdiction’s control and have considerable influence over whether or not housing units in each income category are actually constructed.

What is Senate Bill 375 and how does it relate to RHNA?

Among other things, SB 375, passed into state law in 2008, requires the coordination of housing planning with regional transportation planning through the Metropolitan Transportation Plan and Sustainable Communities Strategy (MTP/SCS). This in effect creates consistency in growth forecasts for land use, housing, and transportation purposes. In prior efforts, the RHNA and the MTP could be conducted independently and often had separate timelines and planning periods. SB 375 requires that the RHNA and MTP/SCS process be undertaken together in order to integrate housing, land use, and transportation planning to ensure that the state’s housing goals are met and to help reduce greenhouse gas emissions (GHG) from cars and light trucks. The goal of this integrated planning is to create opportunities for residents of all incomes to have access to jobs, housing, services, and other common needs by means of public transit, walking, and bicycling. The MTP/SCS is discussed later.

What is the timeline relationship of the RHNA with the MTP/SCS?

Prior to SB 375, the RHNA was updated every five years and the MTP was updated every four years, and neither was required to be tied to the other. Because SB 375 requires better coordination between transportation planning with land use and housing planning, the RHNA process is now tied to the adoption of every two cycles of the regional MTP/SCS. As a result, RHNPs must be adopted every eight years, following the adoption of the update of the MTP/SCS. This also means that each city and county will update its housing element every eight years instead of every five years, as it was before SB 375. Because of the transition period created by SB 375, this RHNA period will be more than exactly eight years – it will cover the period from January 1, 2013 through October 31, 2021. Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 7 What were the key dates in the development of this RHNA and RHNP?

Under SB 375, the date of the MTP/SCS adoption determined the RHNA timeline. The SACOG MTP/SCS was adopted by the SACOG Board of Directors on April 19, 2012. Based on state statutory timelines prescribed in Government Code Section 65584.04, below are the key milestones dates for the RHNA:

 April 2011 to September 2011 – The Regional Planners Committee, comprised of local government planners, met monthly to discuss RHNA and to develop draft RHNA methodologies. The committees of the SACOG Board of Directors were informed regularly on the development of the different draft methodologies;

 September 15, 2011 – SACOG Board of Directors released draft methodologies for 60‐ day public comment;

 December 15, 2011 – SACOG Board of Directors approved Methodology B as selected methodology;

 April 19, 2012 – The MTP/SCS was adopted; SACOG released draft allocations;

 June 18, 2012 – Last day for cities and counties to submit a Request for Revision to the draft allocations; none were received, thereby terminating any further opportunities to modify the draft allocation;

 August 16, 2012 – SACOG Board of Directors to release final proposed RHNP for public comment;

 September 20, 2012 – SACOG to adopt RHNP; and

 October 31, 2013 – Housing element due date for cities and counties within SACOG region.

What was the process used to develop the RHNA methodology?

The most critical factor in the RHNA process is the development of the methodology for dividing housing units within the region. The meetings of the Regional Planners Committee, comprised of local government planning staff but open to the public, served as the forum for the technical development of the draft methodologies. The Regional Planners Committee met monthly and provided input on approaches to different methodologies. SACOG staff developed different alternatives and the associated housing allocations for each one. The Board of Director’s three committees – the Land Use and Air Quality Committee, the Transportation Committee, and the Government Relations and Public Affairs Committee – received regular updates on the development of the RHNA and the methodologies. Six methodologies were developed through the Regional Planners Committee; the SACOG Board selected five methodologies for public comment and further consideration. One methodology,

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 8 Methodology B, was the selected by the Board of Directors and is discussed in further detail below.

How is the allocation for the Tahoe Basin derived?

Because the Tahoe Basin is subject to federal law and to the land use authority of the Tahoe Regional Planning Agency (TRPA), the local governments in Placer and El Dorado Counties have no land use authority to manage growth rates. Therefore, SACOG had no authority to determine the number of overall number of units allocated to the areas in the Tahoe Basin. Rather, SACOG worked with TRPA for its housing projections. TRPA was simultaneously in the process of developing its Regional Transportation Plan, and SACOG utilized its overall growth projections for the RHNA. However, SACOG did apply the same income category distribution methodology to the overall number of units assigned to these jurisdictions.

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 9 Section II:

GROWTH PROJECTIONS FOR THE MTP/SCS AND RHNA

This section provides an overview of how the growth forecasts used in the Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS) were developed and their relation to the RHNA, and provides a description and analysis of the adopted RHNA methodology.

The MTP/SCS is centered on a planning period of 2008‐2035; however, a number of planning processes also rely on phasing assumptions for the year 2020. Therefore a 2020 land use forecast was also developed for the MTP/SCS. The MTP/SCS land use forecast for 2020 serves as the starting point for the 2013‐2021 RHNA as the year 2020 is very close to the 2021 horizon year of the next RHNA period.

SACOG worked closely with the California Departments of Finance and Housing and Community Development to identify the most accurate population, housing, and employment projections for 2020. The same economic and demographic factors used to develop the 2035 regional growth forecast were used to develop the 2020 growth forecast. Given the near‐term time frame of 2020, and the expectation of some recovery from the 2008 economic recession before then, a number of other variables were scrutinized during this process, including vacancy rates, growth rates, household formation behavior, and the health of the home‐building industry. Thus, the 2020 forecast represents an interim snapshot of the MTP/SCS growth forecast.

Development Process for MTP/SCS Growth Forecast

In consultation with local planning departments, SACOG prepares an estimated 2035 growth pattern for the region, which was built by examining a wide range of factors in two areas: market forces and policy/regulatory influences. The Regional Planners Committee was the primary venue for ongoing coordination between local agency planning staff and SACOG; however, a number of jurisdiction‐specific meetings and comment periods were also held.

In December 2009, at the launch of the MTP/SCS update (and to assist with the RHNA development), SACOG staff met with each jurisdiction individually to discuss the update process and to collect new and/or updated planning assumptions. Staff also discussed the upcoming planning process, and worked to keep local agency staff informed of key dates, milestones, and comment periods in the planning process. Throughout the process of developing the land use forecast (from May 2010 to August 2011), SACOG had five review and comment periods directed specifically to local agency planning staff for comments on land use assumptions within each jurisdiction. Additionally, in April 2011, in conjunction with the development of the 2020 land use assumptions, SACOG staff met with each jurisdiction to collect new and/or updated planning assumptions as they relate to the RHNA factors specifically. The adopted MTP/SCS provides more information on the public process, the development of the workshop scenarios, and a Draft Preferred Scenario, as well as the interaction between SACOG and local agency planning staff. Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 10 Growth Forecast Development

The forecasted growth pattern is based on adopted local government general plans, community plans, specific plans, and other local policies and regulations. Other variables are considered to help refine the sum of the local plans in order to create the most likely future development pattern.

SACOG’s MTP/SCS growth forecast can never be just the sum of its 28 member local governments’ adopted general plans at any given point in time. The MTP/SCS and local general plans are two related, but different, kinds of planning documents. General plans are by nature aspirational, have widely ranging timeframes, and are not comprehensively updated very frequently. The MTP/SCS must be a fiscally and time‐constrained plan, with a forecasted growth pattern that is consistent with—not exceeding—the amount of forecasted population, employment, and housing growth for the region by 2035. The transportation investments in the MTP/SCS must be similarly constrained.

Including growth within the MTP/SCS is not a guarantee that it will happen. Likewise, growth in areas outside the MTP/SCS may occur by 2035. The MTP/SCS does not regulate local land use authority or preclude a local jurisdiction from planning and approving growth that is different in terms of total units or geographic extent.

Community Types Framework

SACOG created a framework for describing the MTP/SCS that is made up of Community Types. Local land use plans were divided into one of five Community Types, generally described as follows:

Center and Corridor Communities ‐ are typically higher density and more mixed than other areas.

Established Communities ‐ are typically made up of existing low‐ to medium‐ density residential neighborhoods, office and industrial parks, or commercial strip centers.

Developing Communities ‐ are typically, though not always, situated on vacant land at the edge of existing urban or suburban development; they are the next increment of urban expansion.

Rural Residential Communities ‐ are typically located outside of urbanized areas and are predominately residential, with some small‐scale hobby or commercial farming.

Lands Not Identified for Development in the MTP/SCS Planning Period – are areas of the region not expected to develop to urban levels during the MTP/SCS planning period.

Details of the Land Use Forecast

The land use forecast of the MTP/SCS follows the methodology described above and in greater detail in the MTP/SCS document to assign growth to each of the Community Types. The Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 11 resulting land use forecast focuses on providing a compact land use pattern that provides housing and transportation choice while accommodating the forecasted growth.

A growth pattern that is more compact fosters more walking, biking, transit use, and shorter auto trips by supporting the transportation infrastructure conducive to these modes of travel. The projected addition of more small‐lot and attached housing, increased infill and redevelopment opportunities, and planning for communities with a mix of uses, creates a more compact land use pattern. Just over half of the newly developed land is located in Established Communities and Center and Corridor Communities. The MTP/SCS land use forecast assumes a slightly higher growth rate in Established Communities in the first half of the planning period (by 2020) as it assumes many of the newer subdivisions that have started building in recent years will continue to build at a more steady pace than traditional infill. Similarly, a slower growth rate was assumed for the Center and Corridor Communities in the early years of the plan which reflects the current market conditions. Overall by 2035, the MTP/SCS land use pattern accommodates a 40 percent population increase with only an additional seven percent of land developed (53,266 acres). This greatly contributes to the reduced impact to natural resources.

Providing a variety of housing options, including apartments, condominiums, townhouses, and single‐family detached homes on varying lot sizes, creates opportunities for the variety of people who need them: families, singles, seniors, and people living with special needs.

Recent demographic studies indicate that housing choice will become an increasingly important issue in the future as the population is dominated by older adults and more ethnic diversity. Evolving demographics and preferences held by specific demographic groups or generational cohorts are driving the change in housing preference and demand. Additionally, recent research suggests that not only will people want a choice in terms of location and housing product type, but also that a higher percentage of the population will choose to rent, and will rent for longer periods than has occurred historically. While there is no clear line between housing product type and rental versus ownership, traditionally attached housing units have a higher rental rate than detached housing units. Based on the available evidence, the MTP/SCS estimates that there will be growing demand for attached and small‐lot single‐family housing products over the planning period of the MTP/SCS, along with lower demand for large‐lot single‐family housing products, which currently make up the large majority of the current housing in the region. The MTP/SCS assumes the changing housing product mix is a gradual continuation of current market trends, with higher percentages of attached and small‐lot single‐family products projected in the 2021 to 2035 time period than in the 2008 to 2020 time period.

Converting MTP/SCS Growth Forecast Into RHNA

The MTP/SCS forecast identifies the number of new housing units likely to be built in each jurisdiction during the 2008‐2020 and 2008‐2035 periods. SACOG adopted a methodology that utilizes the information from the 2008‐2020 period to develop the regional housing needs allocation. The next section describes this methodology.

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 12 Section III

RHNA FACTORS

This section describes factors identified in state law (Government Code Section 65584.04(b)(1)), that SACOG must consider to the extent sufficient data is available, when developing its RHNA methodology.

SACOG gathered information relating to the RHNA factors in a variety of ways. First, starting in December 2009, SACOG staff met with the planning staffs for each of the 22 cities and six counties in the region to collect data for both the MTP/SCS and the RHNA. Second, SACOG staff reviewed general plans, specific plans, and other planning documents for each jurisdiction. In May 2011, SACOG staff met again with all jurisdictions in the region to review the RHNA factors and ensure that SACOG had up‐to‐date information on these factors.

The following describes the factors as written in the state housing element law and SACOG’s approach to addressing them in the RHNA.

1. Existing and projected jobs and housing relationship:

SACOG reviewed the jobs and housing balance of all jurisdictions, except for the Tahoe Basin for the reasons explained earlier in Section 1. SACOG’s MTP/SCS growth forecast considers areas where there are significant imbalances in jobs and housing today and the likelihood of those imbalances improving in the future given the recent market conditions and jurisdictions’ local efforts to improve imbalances. Since the MTP/SCS projections represent the most likely growth pattern to occur, it was used as the basis for the overall RHNA distributions.

2. Opportunities and constraints to development of additional housing, including:

a. Lack of capacity for sewer and water due to federal or state laws, regulations or regulatory actions, or supply and distribution decisions made by a sewer or water service provider that preclude the jurisdiction from providing necessary infrastructure for additional development during the planning period.

Some jurisdictions indicated that they would be running out of sewer and/or water capacity during the 2013‐2021 RHNA cycle. However, the RHNA methodology developed by SACOG staff did not cap a jurisdiction’s overall allocation because of diminishing sewer or water capacity (Gov. Code 65584.04(A)(2)). As long as a jurisdiction is able to plan for additional sewer and/or water capacity, no special adjustments were considered in the RHNA methodology. The only case where a jurisdiction is allowed an adjustment is where federal or state regulations prohibit a jurisdiction from providing necessary infrastructure for additional development.

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 13 This only applies in the Tahoe Basin jurisdictions, which are excluded from this methodology for the reasons described in Section I. b. 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 amount of land available for development varies by jurisdiction from relatively large to very limited amounts of vacant land, in addition to infill opportunities from underutilized properties. The MTP/SCS forecasts considered all jurisdictions’ land supplies. Jurisdictions with relatively liberal accessory unit policies or other infill tools are acknowledged in the MTP projections. The MTP/SCS forecasts also reflect slow growth rates in jurisdictions that lack developable lands or redevelopment opportunities due to market forces. A relatively faster growth rate is assumed for jurisdictions with ample land supply and a comparatively strong residential market.

Some jurisdictions noted land set aside for environmental mitigation. These mitigations are reflected in the MTP/SCS allocations in terms of timing of development in specific plan areas. However, jurisdictions that choose to set aside some land from development are not precluded from the planning for potential development in other lands within its boundaries. Jurisdictions are generally not subject to further reductions in their regional housing needs allocations based solely on their lack of developable lands. 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.

The three jurisdictions within the Tahoe Basin (the city of South Lake Tahoe, and portions of Placer and El Dorado counties) are heavily regulated by federal and state laws. The SACOG methodology defers to the agency responsible for growth projections in this area – the Tahoe Regional Planning Agency (TRPA) – for growth allocations for the RHNA.

For the remaining 28 jurisdictions, lands must be officially designated as federal or state conservation lands before any adjustments to the RHNA methodology are considered. Although discussions are taking place regarding federally designated habitat conservation lands, until these lands are designated as such, the RHNA methodology considers those lands eligible for potential residential development. Even if federal designations are given, a jurisdiction still has the ability to plan for residential development on other lands within its boundaries. The RHNA will be Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 14 adjusted only when it is determined no land is available for development within a jurisdiction.

Jurisdictions that choose to impose local restrictions on developable lands are not exempt from the RHNA methodology. Jurisdictions with self‐imposed restrictions may allow other lands for residential development, and as such, will be given an allocation according to the RHNA methodology.

d. County policies to preserve prime agriculture lands within an unincorporated area.

Some counties have policies that are intended to protect against the development of agricultural lands. The MTP/SCS forecast did not assume development of identified agricultural lands.

Some jurisdictions also identified unincorporated agricultural lands that would be developed only upon annexation or incorporation. If the annexing jurisdiction agreed that agricultural land would only be developed upon annexation and no annexation application was in process, this land was not considered available for development for the MTP/SCS forecast and RHNA.

3. Distribution of household growth assumed for a comparable period in the regional transportation plan and opportunities to maximize the use of public transportation and existing transportation infrastructure.

As described Section IV of the RHNP, the foundation of the methodology is the SACOG’s MTP/SCS housing and employment projections. While the RHNA cycle covers from January 1, 2013 through October 31, 2021, the MTP covers the period from 2008 through 2035, with an interim projection from 2008 through 2020. The MTP 2008‐20 projections were developed by collaboration and coordination with each jurisdiction. To coordinate the two projection periods, SACOG took the percentage of the region’s MTP growth for each jurisdiction, and multiplied it by the RHNA six‐county allocation (minus the Tahoe Basin).

The Tahoe Basin is excluded from the MTP projection because it is not part of the federally‐ designated SACOG planning area. SACOG does not have any transportation planning authority within the basin and, therefore, it is not part of the MTP.

4. Market demand for housing

Several jurisdictions commented that the market demand for housing has declined significantly since the 2008 recession. Although there are clear signs that this is the case, this slowdown affects all jurisdictions within the six counties and not any individual jurisdiction significantly more than others. In addition, the 2008‐20 MTP/SCS forecast does take into account the relatively weak short‐term market demand for housing. Therefore, no jurisdictions are given any special adjustments or treatment in this situation.

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 15 5. Agreements between counties and cities to direct growth toward incorporated areas

Some cities and their counties have agreements in place to direct growth towards incorporated areas. Where such agreements exist, SACOG considered unincorporated areas of the county to be unavailable for development in establishing the 2008‐20 MTP/SCS forecast.

6. Loss of units contained in assisted housing developments

During its meetings with individual jurisdictions, SACOG requested data on the potential loss of assisted units. “Assisted units” are multifamily rental housing units that receives governmental assistance under federal programs. SACOG has made subsequent requests, but received no additional data on this issue from member jurisdictions. SACOG looked to other available sources and performed an independent review of each jurisdiction’s housing elements to gather the most current data available on the number of federal and state subsidized housing units, the at‐risk status of such units, and the local inclusionary housing laws and programs for each jurisdiction. SACOG found data outdated or non‐existent. Multiple programs and funding streams make it difficult for jurisdictions and other interest groups to compile accurate lists of the assisted properties in each jurisdiction, especially larger jurisdictions. As such, SACOG determined that the data available is insufficient and cannot be incorporated into the RHNA methodology in a consistent and rationale manner.

However, SACOG is working on a regional analysis of impediments to affordable housing in the region. This is part of a grant that SACOG received from the U.S. Department of Housing and Urban Development. The findings from the study will not be completed in time to incorporate into the RHNA process.

7. High housing cost burdens

SACOG sought to accommodate its projected household growth throughout the region in developing the long‐range growth forecast for the MTP. Thus, in developing the 2008‐20 MTP/SCS household projections, SACOG worked with its member cities and counties to identify the most likely places where housing would occur, based on local and regional market demand, Blueprint/Smart Growth Principles, and the planning activities of each jurisdiction to ensure that housing costs would not be inflated as a result of housing shortages.

8. Housing needs of farmworkers

The need for farm laborer housing in the SACOG region is a greater issue for farming operations in the valley than in the foothills due to the types of crops and amount of production in these areas. Housing authorities in the region provide some publicly owned and/or managed dedicated farm laborer housing. Some of these units provide seasonal housing and others permanent housing. Nonetheless, Sutter County Housing Authority and Yolo County Housing Authority reported having waiting lists for their permanent housing units in 2008, when research was first started for this paper. Farm labor camps are permitted by use permit in all of the region’s counties.

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 16 Each county has policies encouraging some farm laborer housing on‐site (via an accessory unit) and all of the agricultural zoning codes in the region allow for secondary units on‐site, either by right or with an additional permit. The number of secondary units that currently exist in the region and the percentage of these used for farm laborer housing is unknown. To support the goal of a healthy farm economy, the agriculture element of Yolo County's draft general plan contains policies to streamline permitting requirements for farm laborer housing, including reducing fees and requiring inclusionary housing within established communities (Policy AG‐ 3.5). The draft element further encourages cities to share in the responsibility for providing adequate sites to accommodate farm labor housing (Policy AG‐3.6). Through their housing elements, all of the counties have policies that encourage the use of state and federal housing aid programs to provide farm laborer housing. These policies and practices are reflected in the 2008‐20 MTP/SCS forecast.

9. Housing needs generated by the presence of a private university or a campus of the California State University or the University of California

The plans made by California State University or University of California campuses for student housing are modeled into the MTP projections, and are thereby incorporated into the methodology.

10. Any other relevant factors, as determined by SACOG.

Flood protection and management may affect the RHNA methodology and the associated allocations. The Federal Emergency Management Agency (FEMA) is reviewing the flood levees and may re‐designate and impose a federal moratorium on residential development in certain areas. If, during the RHNA update process, a jurisdiction receives a FEMA designation that prohibits near‐term development, the RHNA methodology may need to be revised.

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 17 Section IV

ADOPTED RHNA METHODOLOGY AND ALLOCATIONS

This section describes the approved RHNA methodology by the SACOG Board of Directors for the period covering January 1, 2013 to October 31, 2021. Methodology B was the selected methodology amongst the five draft alternatives presented to the SACOG Board of Directors. In this section, the methodology is first summarized in general terms. Then a step‐by‐step description is provided to describe how the math is performed using the methodology. A brief analysis of the methodology is also provided, followed by a glossary of terms. Finally, Tables 2 and 3 correspond to the descriptions and show the allocations assigned to each jurisdiction.

Description of Approved 2013‐21 RHNA Methodology (Methodology B)

Summary: This methodology starts all jurisdictions with a percentage of affordable units equal to the percentage of existing affordable income households in the region. It then applies an adjustment factor based on regional income distribution disparities. The adjustment factor adds future affordable units to jurisdictions that currently have lower than the regional average, and subtracts future affordable units from jurisdictions that have higher than the regional average. This methodology moves all jurisdictions towards achieving the regional average, but rather than every jurisdiction achieving regional parity by 2050, each jurisdiction will reach the regional average at different points in time.

How It Works: (See Table 2 at the end of this section.)

The methodology uses a two‐step process. Step 1 establishes the “affordable base” number. Step 2 applies an adjustment factor to move household income distributions toward regional equity. In other words:

overall allocation*regional average of affordable units = affordable base

then,

affordable allocation = affordable base +/‐ income adjustment

Step 1 distributes evenly the regional percentage of affordable units to each jurisdiction. The affordable income category adds up to 39.8 percent for the region, as determined by HCD. In this methodology, every jurisdiction’s “base” or “affordable base” number is calculated by multiplying 39.8 percent by the jurisdiction’s overall allocation number (See Table 2; Column A multiplied by Column C).

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 18 Step 2 is a two‐part process (2a and 2b) to adjust the affordable base allocation by a factor that addresses regional income parity. In other words, the adjustment factor trends all jurisdictions towards the regional average of affordable housing units (39.8%).

Step 2a contains the same calculations used in the 2006‐13 RHNA methodology. This method determines the allocation of affordable units by drawing an “income trendline” from 2008 to 2050, referred to as the “2050 income trendline.” On one endpoint, the 2006‐2008 Census American Community Survey (ACS) shows the percentage of households that a jurisdiction has in each of the four income categories as of 2008. The other endpoint, 2050, shows the projected regional average percentage of households in each income category as determined by HCD; again, the affordable income categories are 39.8 percent. The 2050 income trendline is drawn connecting these two points – the jurisdiction’s current affordable income percentage share of affordable income housing units in 2008 to the 39.838 percent of its housing units in 2050. This line is then intersected at October 31, 2021, the end period for this RHNA cycle. The point of intersection is the percentage of growth that the jurisdiction would need of new affordable housing units to be trending toward the regional average of affordable housing units by 2050. In other words, the results of Step 2a (Column D) shows the percentage of growth that the jurisdiction would need of new affordable housing units to be trending towards the regional average of affordable housing units by 2050.

Note: this method places a 4 percent floor and 30 percent ceiling in both low and very low‐ income categories (or a total floor of 8% and 60% ceiling for total affordable units) – these floor and ceiling limits were used during the 2006‐13 RHNA cycle.

Step 2b compares the resulting percentage in Step 2a against the regional average of affordable households (39.838%). The difference, the “income variance,” is expressed as a percentage (Column E). A jurisdiction that has a percentage from Step 2a that is lower than 39.8 percent, means that jurisdiction has a higher percentage share of affordable units than the regional average and, therefore, to get to regional income parity in 2050, it would need less than the regional average between now and 2050. Such a jurisdiction would receive a negative income adjustment factor number (Column F). Conversely, a jurisdiction with a lower share of affordable units when compared to the regional average, would receive a higher percentage than the regional average between now and 2050. Note that Step 2a also places a 4 percent floor and 30 percent ceiling (or “guardrails”) in low and very low‐income categories, as described in Methodology A.

Table 3 shows the result of the above described methodology for each of the four income categories. This table only shows the resulting figures and not the interim calculation steps.

Analysis: As the approved methodology, Methodology B focuses on the regional land use pattern and where transportation infrastructure investments will be made. Locating jobs and services near low‐income communities and providing non‐auto transportation alternatives to these areas is an important social equity consideration that is included in the MTP/SCS land use pattern and growth assumptions. One way to ensure consistency between the MTP/SCS and RHNA is to keep the land use assumptions of the MTP/SCS intact as the starting point for not Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 19 just the overall allocation, but for the affordable allocation as well. This methodology equally distributes the number of affordable income units to each jurisdiction, thereby preserving the distribution of housing growth among jurisdictions. To balance this goal with another state housing law objective to avoid over‐concentrating affordable income housing, draft Methodology B then applies an adjustment factor to the affordable incomes units in each jurisdiction. The adjustment factor is based on the methodology from the 2006‐13 RHNA methodology, which aims to move all jurisdictions towards regional income parity in terms of their share of affordable housing units. One potential disadvantage to this methodology is that it changes the rate by which jurisdictions achieve regional income parity.

Key Terms Explained

‐ 2050 Income Trendline: the percent share of a jurisdiction’s new growth that must be affordable during the 2013‐21 RHNA cycle for the jurisdiction to reach the regional average of affordable units by 2050.

‐ Affordable Base: the calculation of affordable units each jurisdiction starts with before adjustment. It is 39.8 percent of a jurisdiction’s overall allocation, which is the percentage of affordable‐income households in the region.

‐ Affordable Income Categories: very low and low‐income categories combined.

‐ CHAS – Comprehensive Housing Affordable Strategy data provided by the U.S. Department of Housing and Urban Development. This is a special tabulation of Census data from the U.S. Census Bureau geared towards housing planners and policy makers. The primary purpose of the CHAS data is to demonstrate the number of households in need of housing assistance. One way in which they do this is to provide the number of households by household size that fall within 30, 50, and 80 percent of local median income. This data differs from traditionally available Census data that depicts household income without accounting for household size. For more information please visit: http://www.huduser.org/portal/datasets/cp/CHAS/bg_chas.html.

‐ Income Categories: state housing element law defines four income categories: very low, low, moderate, and above moderate. Each is defined by comparing median family income (MFI) to a household with the same number of members in the same county. “Very low” income households have incomes 50 percent or lower than MFI. “Low” income households have incomes between 50 percent and 80 percent of MFI. “Moderate” income households have incomes between 80 percent and 120 percent of MFI. “Above moderate” income households have incomes greater than 120 percent MFI.

‐ Region: for RHNA purposes, SACOG includes El Dorado, Placer, Sacramento, Sutter, Yolo and Yuba counties, including the Tahoe Basin in El Dorado and Placer counties.

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 20 ‐ Regional Average of Affordable Housing Units: percentage of housing units in the region that falls into the affordable income categories. This number is 39.8 percent according to HCD, which uses the five‐year 2005‐2009 American Community Survey data.

‐ Regional Income Parity: all jurisdictions in the region have the same proportion of affordable income households as the regional average. When describing how to achieve “regional income parity by 2050,” this document is referring to what percentage of total units a jurisdiction would need to meet the regional average by 2050. This percentage is different for each jurisdiction, as they currently have different affordable income shares and different growth rates.

‐ Variance: the numerical difference between a jurisdiction and the regional average for the three measured characteristics (jobs/housing ratio, transit service area, and income). The variance is either multiplied by the “affordable base”, “non‐affordable base” or the 2050 income trendline to determine an adjustment factor.

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 21 Table 2: Approved RHNA Methodology ‐ Step by Step Allocation Calculations SACOG 2013‐2021 RHNA RHNA Period: January 1, 2013 through October 31, 2021

Draft Allocation based on Approved Methodology (Jan 1, 2013 to Oct 31, 2021 RHNA Cycle) Overall Base Number: Equal Share Very Low+Low Income Adjustment Factor: Regional Equity Allocation for all Jurisdictions Alloctions Targeted % of Base units Total number of allocation for Base distributed in Income Allocation VL + Units (based on Adjusted Allocation VL + Very Allocation VL+L by Variance from L by Percent of proportion of Factor (Col L units (Col B + Low+Low Very Low + October 31, (Col D‐ Total (Col G/Col MTP/SCS 2020 B*Col E) Col F) 2021 for 39.838%) A) projection) (Col A * Col Low % C) regional parity by 2050 ABCDEFGH x=39.8% Placerville 372 148 39.8% 29.3% ‐10.5% ‐15 133 35.8% South Lake Tahoe1 336 134 39.8% 8.3% ‐31.5% ‐42 92 27.4% El Dorado Uninc Tahoe Basin1 480 191 39.8% 57.6% 17.8% 34 225 46.9% El Dorado Uninc 3,948 1,571 39.8% 43.1% 3.3% 52 1,623 41.1% El Dorado County total 5,136 2,044 39.8% 41.2% 2,073 40.4%

Auburn 308 123 39.8% 42.4% 2.6% 3 126 40.9% Colfax 51 20 39.8% 23.1% ‐16.7% ‐3 17 33.3% Lincoln 3,790 1,508 39.8% 47.3% 7.5% 113 1,621 42.8% Loomis 154 61 39.8% 47.1% 7.3% 5 66 42.9% Rocklin 3,813 1,518 39.8% 56.4% 16.6% 251 1,769 46.4% Roseville 8,478 3,374 39.8% 54.2% 14.4% 484 3,858 45.5% Placer Uninc Tahoe Basin1 328 131 39.8% 57.5% 17.7% 22 153 46.6% Placer Uninc 4,703 1,872 39.8% 55.7% 15.9% 297 2,169 46.1% Placer County total 21,625 8,607 39.8% 53.5% 9,779 45.2%

Citrus Heights 696 277 39.8% 29.2% ‐10.6% ‐29 248 35.6% Elk Grove 7,402 2,946 39.8% 57.4% 17.6% 516 3,462 46.8% Folsom 4,633 1,844 39.8% 52.2% 12.4% 228 2,072 44.7% Galt 679 270 39.8% 22.1% ‐17.7% ‐48 222 32.7% Isleton 23 9 39.8% 19.4% ‐20.4% ‐2 7 30.4% Rancho Cordova 7,008 2,789 39.8% 33.7% ‐6.1% ‐171 2,618 37.4% Sacramento 24,101 9,593 39.8% 27.5% ‐12.3% ‐1,182 8,411 34.9% Sacramento Uninc 13,844 5,511 39.8% 37.1% ‐2.7% ‐154 5,357 38.7% Sacramento County total 58,386 23,240 39.8% 36.2% 22,397 38.4%

Live Oak 449 179 39.8% 38.3% ‐1.5% ‐3 176 39.2% Yuba City 2,679 1,066 39.8% 39.4% ‐0.4% ‐5 1,061 39.6% Sutter Uninc 335 133 39.8% 48.2% 8.4% 12 145 43.3% Sutter County total 3,463 1,378 39.8% 40.1% 1,382 39.9%

Davis 1,066 424 39.8% 39.3% ‐0.5% ‐2 422 39.6% West Sacramento 5,977 2,379 39.8% 34.0% ‐5.8% ‐140 2,239 37.5% Winters 319 127 39.8% 42.0% 2.2% 3 130 40.8% Woodland 1,877 747 39.8% 28.7% ‐11.1% ‐83 664 35.4% Yolo Uninc 1,890 752 39.8% 36.3% ‐3.5% ‐26 726 38.4% Yolo County total 11,129 4,429 39.8% 34.2% 4,181 37.6% 0 Marysville 72 29 39.8% 8.1% ‐31.7% ‐9 20 27.8% Wheatland 483 192 39.8% 35.9% ‐3.9% ‐7 185 38.3% Yuba Uninc 4,676 1,861 39.8% 34.5% ‐5.3% ‐98 1,763 37.7% Yuba County total 5,231 2,082 39.8% 34.3% ‐5.5% 1,968 37.6%

SUM 104,970 41,780 39.8% 39.8% 0 41,780 39.8%

Sacramento Area Council of Governments 1 ‐ Tahoe Basin allocations based on projections provided by the Tahoe Regional Planning Agency Table 3 ‐ Allocations by Four Income Categories SACOG 2013‐2021 RHNA ‐ FINAL ALLOCATIONS

SUM 104,970 24,560 23.4% 17,220 16.4% 19,520 18.6% 43,670 41.6% 41,780 39.8% Section V

COMMENTS/QUESTIONS REGARDING APPROVED METHODOLOGY

This section summarizes the key questions and comments that SACOG received during the development of the RHNA pertaining to the selected methodology (Methodology B). Please note that additional written comments regarding all draft methodologies received by SACOG, and SACOG’s responses, are included in the Appendices 2C and 2D.

Comment: The minimum Regional Housing Needs Allocation for the six‐county region is 104,970 – that does not seem as low as might have been expected given the economy.

Response: This overall regional allocation was the result of much collaborative discussion and data sharing with the California Housing and Community Development Department (HCD), the agency which issues the allocation. While the number may seem high in light of today’s economic situation, the number is about 25 percent lower per year when compared to the 2006‐13 regional allocation. In addition, the next RHNA period does not start until the January 1, 2013, by which time the economy is expected to show some recovery. The planning period ends October 31, 2021 and SACOG’s current projections indicate development activity continuing to recover within this time period. It is also important to remember that the transportation projects in the Metropolitan Transportation Plan (MTP) are based on these growth projections. Reductions in growth rates will require corresponding reductions in estimated revenues for the MTP.

One additional consideration to note is that zoned housing units that jurisdictions received “credit” for in the 2006‐13 RHNA cycle that have not received a building permit may be counted again in the 2013‐21 RHNA period. Because many jurisdictions with certified housing elements may have only had a relatively small portion of their zoned parcels constructed, these same parcels/units are eligible to be counted in the upcoming RHNA cycle.

Comment: Why is SACOG staff proposing something other than the methodology used in the 2006‐13 RHNA cycle for distributing the affordable allocations?

Response: The methodology used in 2006‐13 was based solely on moving each jurisdiction towards regional parity in terms of its share of affordable housing and the methodology did not consider the land use pattern and transportation investments in the MTP/SCS in its allocation of low and very low‐income units. SB 375 now requires the RHNA methodology to be consistent with the land use pattern and transportation investments in the draft MTP. As a result, the 2006‐13 methodology did not directly consider smart growth planning principles or any of the other social equity factors built into the land use and transportation assumptions of the MTP. One potential disadvantage to using the 2006‐2013 methodology with the new MTP/SCS land

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 24 use and transportation assumptions would be locating existing and future lower‐income residents away from jobs, services, and transit.

Comment: SACOG staff is proposing draft Methodology B, which uniformly starts all jurisdictions with the same base percentage of total units as the affordable allocation based on the regional average, then applies an adjustment factor based on regional fair share housing. Why add in the regional equity adjustment factor step?

Response: Methodology B is consistent with the MTP, which is required by SB 375. In creating the land use assumptions for the MTP/SCS, staff has considered the location, type, and amount of development in the region. In developing the growth pattern, staff considers local policies and plans, state and federal regulations (such as flood or habitat constraints), and market and economic conditions. The result is a land use pattern that reflects the Blueprint principles and is a reasonable assumption for development. The transportation investments pair with the land use assumptions and together result in transportation and air quality benefits such as reductions in vehicle miles traveled and greenhouse gas emissions and increases in transit, walking, and biking.

The funding available for transportation projects in the region in this MTP cycle is $5 billion less than in the last MTP. As a result, the amount of money dedicated to transit, although increased in share in this MTP, is still considerably less than what was assumed in the last MTP. This makes it very important that SACOG maximizes the benefit of these funds. Since transit is most efficient in locations with higher densities, locating more new homes and jobs near transit will maximize the productivity of transit investments. Therefore, the land use pattern assumes a higher proportion of overall growth happening in urban areas where much of the transit investments are planned. The outcomes of this include a reduction in vehicle miles traveled and greenhouse gas emissions, an increase in “farebox recovery” (the ability for fares to pay for the full operating cost of transit), and most importantly from a RHNA perspective, more new high quality transit to existing concentrations of low‐income residents. This increases overall affordability, when the costs of housing plus transportation costs are considered together. Locating jobs and services near low‐income communities and providing non‐auto transportation alternatives to these areas is an important social equity consideration that is included in the MTP/SCS land use pattern and growth assumptions.

One way to ensure consistency between the MTP/SCS and RHNA is to keep the land use assumptions of the MTP/SCS intact as the starting point for the RHNA total allocation and the very low and low‐unit allocation. To achieve this, Methodology B equally distributes the number of low and very low‐income units to each jurisdiction. However, state housing element law objectives include avoiding over‐concentrating low and very low‐income housing. To adjust for this, Methodology B then applies an adjustment factor to the very low and low‐income units in each jurisdiction. The adjustment factor is based on the methodology from the 2006‐13 RHNA methodology, which aims to move all jurisdictions towards regional parity in terms of their share of affordable housing by 2050. Methodology B therefore reflects the objectives of

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 25 the MTP/SCS, while providing an adjustment factor for income in effort to meet the multiple objectives of SB 375 and housing element law.

Comment: It appears that Methodology B, as compared to the 2006‐13 methodology, allows communities with current low‐income housing unit deficiencies to get fewer units and “fall behind” in terms of reaching regional parity by 2050.

Response: Methodology B does not allow any jurisdiction to fall behind in terms of receiving its fair share of affordable units. It does change the rate at which all jurisdictions get to regional parity. The methodology is still moving jurisdictions towards the goal of parity by 2050 while recognizing the other important social equity considerations relating to affordability and transportation alternatives.

Comment: How was the 39.8 percent arrived at as the region’s low and very low‐income share?

Response: HCD used the U.S. Census Bureau’s American Community Survey (ACS) 2005‐2009 five‐year average data to determine the median household income by Metropolitan Statistical Area (MSA) and derived the four income categories. There are two MSA’s in the SACOG Region – The ‘Yuba City MSA,’ which includes Sutter and Yuba counties, and the ‘Sacramento‐Arden Arcade‐Roseville MSA,’ which includes El Dorado, Placer, Sacramento, and Yolo counties. Median household income numbers were calculated at 50 percent, 80 percent, and 120 percent to arrive at thresholds for each income category. 2005‐2009 ACS income range data for each MSA were then used to place households in each of the four income categories. The number of households in each category was then summed to arrive at a regional total and divided by the total number of households in the region to arrive at the percentage of households falling within each category, which resulted in 22.0 percent very low income, 17.8 percent low income, 18.6 percent moderate income, and 41.5 percent above moderate income.

Comment: Will there be new CHAS data that can better reflect what the current income distributions are in the region?

Response: The most recent available CHAS data comes from a special run of the 2006‐2008 three‐year average ACS data. This data is only available for jurisdictions with a population of 20,000 or more. The 2005‐2009 five‐year average ACS data, which would have updated data for all jurisdictions in the SACOG region, is not currently available in CHAS format, but is expected to be released at the end of summer 2011.

Comment: Housing prices have dropped dramatically in many places. Is there a way to show that housing prices – including for single family detached – are much lower and that jurisdictions should get more credit for the amount of existing affordable housing? Can data from the Metro Listing Service be used?

Response: The housing element law only considers higher density land and deed restricted affordable housing as affordable housing. Lower housing prices are not factored in housing

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 26 element reviews. The regional total housing unit growth for the region does account for the current high vacancy rate in that households are assumed to “fill up” existing vacant units over the planning period, reducing demand for even more housing units.

Comment: Is there a way to factor in jobs, wages, and incomes into what types of housing should be located in each jurisdiction?

Response: SACOG is developing a “jobs/housing fit” analysis as part of its federal Sustainable Communities Initiative grant; however, the data and analysis will not be ready in time for it to factor into this RHNA cycle. Jobs/housing fit considers the types of jobs, and their associated wages, to determine what types of housing choices would match income earning.

Draft 2013‐21 SACOG Regional Housing Needs Plan Draft Version July 26, 2012 Page 27

APPENDIX 1

Regional Housing Needs Determination Letter

STATE OF CALIFORNIA -BUSINESS, TRANSPORTATION AND HOUSING AGENCY EDMUND G. BROWN JR., Governor DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF HOUSING POLICY DEVELOPMENT 1800 Third Street, Suite 430 P. O. Box 952053 Sacramento, CA 94252-2053 (916) 323-3177 / FAX (916) 327-2643 www.hcd.ca.gov

September 26, 2011

Mr. Mike McKeever Executive Director Sacramento Area Council of Governments 1415 L. Street, Suite 300 Sacramento, CA 95814

Dear Mr. McKeever:

RE: Regional Housing Need Determination for Housing Element Updates

This letter provides the Sacramento Area Council of Governments (SACOG) its Regional Housing Need Assessment (RHNA) Determination for the projection period beginning January 2013 and ending October 2021. Pursuant to State housing element law (Government Code Section 65584, et seq.), the Department of Housing and Community Development (Department) is required to determine SACOG’s existing and projected housing need.

As you know, Chapter 728, Statutes of 2008 (SB 375) strengthened coordination of housing and transportation planning and requires Metropolitan Planning Organizations (MPOs) to develop a new sustainable communities strategy (SCS) in the Regional Transportation Plan (RTP) to achieve greenhouse gas emission reductions and ensure the SCS accommodates the regional housing need determination. Amendments to the law included revisions to the Department’s RHNA schedule and methodology and also definitions addressing the RHNA projection period, housing element planning period, and coordination with updating the regional transportation plan. For SACOG, the Department’s RHNA Determination is made on the basis of partial demographic data available at this time from Census 2010 complemented by American Community Survey (ACS) data. In assessing SACOG’s regional housing need, the Department considered the critical role housing plays in developing sustainable communities and supporting employment growth.

Working in coordination with SACOG, the Department has determined a range of new housing need (104,970 – 117,850 units) for the period 2013-2021. This range considered the extraordinary uncertainty regarding national, State, and local economies and housing markets. For this RHNA cycle only, the Department made an adjustment to account for abnormally high vacancies and unique market conditions due to prolonged recessionary conditions, high unemployment, and unprecedented foreclosures.

Mr. Mike McKeever Page 2

The RHNA low range (104,970) reflects the Department’s acceptance of SACOG’s projections and assumptions as the minimum need after evaluating the reasonableness of data, assumptions and support documentation submitted by SACOG. This figure considers household growth for the projection period using derived household formation rates based on State 2005-2009 ACS estimates and existing high unit vacancies resulting from the unusual turmoil in housing markets. The low range also accounts for SACOG assessing housing need due to unbundling of “doubled-up” households, resumption of more normal household formation rates, and vacancy rates returning to normal historical levels for the region before the end of the projection period. The RHNA high range (117,850) reflects the Department’s consideration of SACOG’s strong socio-economic base and potential for demographic trends to grow at a faster and more diverse pace, particularly among older age groups, to generate higher housing demand. The Department encourages SACOG to plan for housing need above the minimum of the range to accommodate potential higher demand.

SACOG’s methodology and plan to allocate to each locality a share of new housing need must, in the aggregate, at least equal the total of the low range in Attachment 1. The plan must also allocate to each jurisdiction a share of very-low, low, and moderate-income at least equal the income category figures of the low range. For each jurisdiction, the RHNA represents the minimum amount of residential development capacity to zone for; RHNA figures are not to be used within local general plans as the maximum amount of residential development to plan for or approve.

In determining SACOG’s housing needs, the Department applied methodology and assumptions that considered all of the factors specified in Government Code Section 65584.01(c)(1). In addition, the Department consulted with SACOG staff and Department of Finance (DOF) as required by statute. The first meeting occurred in late January 2011 with Mr. Greg Chew, SACOG Senior Planner. Subsequent meetings and correspondence involved Mr. Gordon Garry, SACOG Research Manager and Ms. Tina Glover, SACOG Demographer. The Department also consulted with Mr. Stephen Levy, Director for the Center for Continuing Study of the California Economy (CCSCE), who prepared employment, population, and household projections for SACOG.

The data, assumptions, and descriptive information provided by SACOG and CCSCE, included indicators regarding the region’s relationship between jobs and housing, and commute patterns. Of particular relevance are SACOG efforts to reassess the job-housing balance as more than a quantitative indicator of the relationship between jobs and housing, and to develop a qualitative approach, the “job-housing fit” concept, to use in its transportation plan update. In addition, assumptions were made about the rate with which existing “for sale” and “for rent” housing units may be absorbed by the beginning of the projection period in 2013.

The Attachments to this letter describe the RHNA methodology used by the Department and the income category distribution to be used by SACOG in allocating among all local governments within the region at least the minimum total RHNA and minimum amounts for very-low, low, and moderate income categories.

ATTACHMENT 1

HCD REGIONAL HOUSING NEED DETERMINATION: SACOG Projection Period: January 1, 2013 through October 31, 2021

Income Category Percent Range of Housing Need (rounded) (1)

Very-Low 23.4% 24,560 - 27,580 Low 16.4% 17,220 - 19,330 Moderate 18.6% 19,520 - 21,920 Above-Moderate 41.6% 43,670 - 49,020

Total 100.0% (2) 104,970 (3) 117,850 (4)

(1) The statutory objective regarding RHNA requires HCD, in consultation with Department of Finance (DOF) and councils of governments (COGs), to determine projected household growth and housing need based on DOF population projections and COG regional population forecasts and requires regional and local jurisdictions to plan to accommodate capacity for all of the projected RHNA. The Legislature recognizes that different assumptions and variances in methodologies can be used that can result in different population projections. Projection of housing need developed by DOF and HCD for RHNA purposes does not consider local government constraints. The Legislature acknowledges that regional and local jurisdictions have the responsibility to consider economic, environmental, fiscal factors, and community goals in developing regional and local plans, and that future housing production may not equal the regional housing need established for planning purposes.

For this RHNA cycle only (due to unique conditions not expected to recur to impact future RHNA cycles), the housing need was adjusted downward to account for different absorption estimates for unprecedented high vacancies in existing stock due to extraordinary conditions including high foreclosures and recession uncertainties.

(2) The income category percentages reflect the minimum percentage to apply against the total RHNA decided by SACOG (at or above the minimum range) in determining housing need for very-low, low, and moderate income households. Each category is defined by Health and Safety Code (Section 50093, et seq.). Percentages are derived from the 2005-2009 American Community Survey’s number of households by income, over 12 month periods, by Metropolitan Statistical Area. Housing unit need under each income category is derived from multiplying the portion of households per income category against the total RHNA determination.

(3) The 104,970 low end of the range (see Attachment 2) reflects SACOG’s projected minimum housing need (rounded), using 2005-2009 household formation rates from American Community Surveys (ACS) adjusted to match SACOG population and household inventories. It reflects an adjustment (-16,010) for existing excess vacant units in estimating 85% of vacant units will not be absorbed before 2013. This column represents the minimum housing need that SACOG’s RHNA Plan must address in total and also for very-low, low, and moderate income categories. (4) The 117,850 high end of the range (see Attachment 3) reflects HCD’s determined higher housing need (rounded), using the 2005-2009 ACS household formation rates applied to SACOG’s population projections. It reflects an adjustment (-3,770) for existing excess vacant units in estimating a faster absorption rate and that only 20% of vacant units will not be occupied by 2013. In planning for RHNA above the low range, income category percentages for very-low, low, and moderate income households remain the same. ATTACHMENT 2

HCD REGIONAL HOUSING NEED DETERMINATION (LOW RANGE): SACOG

HCD Determined Population, Households, & Housing Need (rounded): January 1, 2013-October 31, 2021 (8.8 years) 1 Population: October 31, 2021 (SACOG Projection) 2,713,330 2 less: Group Quarters Population (SACOG's estimate) -57,210 3 Household (HH) Population 2,656,120 Household Formation Groups HH PopulationHH Formation Households or Headship Age Groups (DOF) 2,656,120Rate (ACS) 1,008,780 Under 15 502,318 - - 15 - 24 years 337,782 11.59% 39,130 25 - 34 years 360,451 42.07% 151,650 35 - 44 years 325,195 51.04% 165,980 45 - 54 years 327,870 54.87% 179,900 55 - 64 years 343,922 56.27% 193,530 65 and older 458,581 60.75% 278,590 4 Projected Households 1,008,780 5 less: Households at Beginning of Projection Period (January 1, 2013 interpolated) -891,770 6 Household Growth: 8.8 Year Projection Period (New Housing Unit Need) 117,010 7 Vacancy Allowance Owner Renter Total Tenure Percentage 60.73% 39.27% HH Growth (New Unit Need) 71,060 45,950 117,010 Vacancy Rate (SACOG) 1.50% 5.00% Vacancy Allowance 1,070 2,300 3,370 3,370 8 Replacement Allowance (minimum) 0.50% 120,380 600 9 less: Adjustment for Absorption of Existing Excess Vacant Units Effective Healthy Estimate 15% Absorbed, 85% Not Absorbed by 2013 Vacant Units Market Units Differential Derived (2010 Census, Vacancy Rates) (42,110) 25,430 -16,680 Total Exisitng (2011) Housing Stock 935,759 Existing Vacant Unit (Others) Adjustment 1.72% 1.49% Total Adjusted Existing Vacant Units (Others) (16,100) 13,940 -2,160 Estimated Units (Others) Not Absorbed by 2013 85% -18,840 -16,010 FINAL REGIONAL HOUSING NEED DETERMINATION (Low Range of New Housing Unit Need) 104,970

Explanation and Data Sources 1 Population : Population reflects SACOG's October 2021 projection. Pursuant to Government Code 65584.01(b), SACOG’s 2021 population projection was compared to the 2021 population derived from Department of Finance (DOF) 2011 Interim Projections published June 2011 for 2020 and DOF’s E5 estimate for 2011. Based on SACOG’s population projection being within 3% of the DOF Population Interim projections and consultation with SACOG, SACOG’s population projection was used in determining housing need for the region. 2 Group Quarter Population : Figure is SACOG's estimate of persons residing in a group home, institution, military, or dormitory using the DOF 2010 E5 estimates for 2010, and maintaining its proportion in the total population constant throughout the projection period. As this population doesn't constitute a "household" population generating demand for a housing unit, the group quarter population is excluded from the calculation of the household population, and is not included in the housing need.

3 Household (HH) Population : The population projected to reside in housing units after subtracting the group quarter population from total projected population. ATTACHMENT 2

HCD REGIONAL HOUSING NEED DETERMINATION (LOW RANGE): SACOG

4 Projected Households (HHs) : Calculated by applying (to the 2021 HH population) HH formation rates derived by SACOG using the state 2005-2009 American Community Survey (ACS) rates controlled for SACOG population and household inventories. HH formation rates were evaluated for reasonableness in conjunction with ACS HH formation rates for the region provided by DOF and with the vacancy assumptions as described below. For October 2021, the household number and its distribution by age group were estimated based on the 2020 projections. 5 Households at Beginning of Projection Period: For the first time since inception of RHNA, the baseline number of households at the beginning of the projection period (January 2013) must be projected, as a direct effect of amendment to Section 65588(e)(6), specifying the new projection period to start on either June 30 or December 31 whichever date most closely precedes the end of the current housing element period (June 30, 2013 for SACOG). As such, the January 1, 2013 household number was calculated as an interpolation between the SACOG 2008 baseline number of households and the projected 2021 number of households, assuming growth at a slower pace between baseline and 2013, and faster pace between 2013 and 2021 (approximating 24,000 annual households between 2008 and 2013, and 31,000 annual households over the projection period 2013-2021). 6 Household (HH) Growth : This figure reflects projected HH growth and need for new units.

7 Vacancy Allowance: An allowance (unit increase) is made to facilitate availability and mobility among owner and renter units. Owner/Renter % is based on Census 2010 data. A smaller rate is applied to owner units due to less mobility than for renter households. Information from a variety of authoritative sources supports an acceptable range of 1 to 4% for owner units and 4 to 8% for renter units depending on market conditions.

8 Replacement Allowance : Rate (0.5%) reflects housing losses that localities annually reported to DOF each January for years 2000-2010, or 0.5%, whichever is higher.

9 Adjustment for Absorption of Existing Excess Vacant Units: For this RHNA cycle only (due to extraordinary uncertainty regarding conditions impacting the economy and housing market not expected to similarly impact future RHNA cycles), a new one-time adjustment was made to account for unprecedented high vacancies in existing stock, due to unusual conditions including high foreclosures and recession uncertainties. A slow absorption rate of 15% of existing excess vacant units is assumed to occur in shrinking current excess vacant units before the start of the 2013 RHNA projection period resulting in applying a 85% adjustment to account for units not absorbed that decreases new housing need by -16,010 units. Existing housing stock consists of two components: (1) housing units for sale and rent in existing housing stock that are above the housing units required to maintain the healthy market condition, calculated as the number of units in housing stock (for sale+for rent+sold, not occupied+rented, not occupied + occupied units), (2) housing units in the "vacant units others" category of existing housing stock above the simple average of 1.49% calculated based on Census data from 1990 to 2010. To evaluate the reasonableness of vacancy adjustments proposed by SACOG to account for the unprecedented economic downturn, the Department used 2010 Census Demographic profile data (DP-1) and desirable "normal" vacancy rates by tenure, in conjunction with the region's household growth and proposed household formation rates. The proposed vacancy adjustment is limited to not exceed the differential between the 2010 Census vacant units and the healthy market vacant units rate associated with the region's annual household growth. As the adjustment was below the differential, the vacancy adjustment was applied in calculating the low RHNA range.

RHNA Projection Period January 1, 2013 to October 31, 2021 : Pursuant to SB 375, the start of the projection period (in effect January 1, 2013) was determined pursuant to GC 65588(e)(6), which requires the new projection period to start on June 30 or December 31 that most closely precedes the end of the current housing element period, which for SACOG region is June 30, 2013. The end of the projection period was determined pursuant to GC 65588(e)(5) to be the end of the housing element planning period . Note: For projection purposes the end of the projection period is rounded to the nearest start/end of the month.

Housing Element Planning Period October 31, 2013 to October 31, 2021 : Pursuant to SB 375, the start of the planning period was determined pursuant to GC 65588(e)(5), 18 months from the estimated adoption date of the SACOG’s Regional Transportation Plan based on SACOG’s notice to the Department (April 19, 2012) with the date rounded to the nearest start/end of month for projection purposes. The end of the planning period was calculated pursuant to GC 65588(e)(3)(A), 18 months after the adoption of the second MTP, provided that it is not later than eight years from the adoption of the previous housing element. If the actual MTP adoption date differs from the estimated date, the RHNA determination and the projection period will not change, however the housing element due date, and implicitly, the housing element planning period would change. ATTACHMENT 3

HCD REGIONAL HOUSING NEED DETERMINATION (HIGH RANGE): SACOG HCD Determined Population, Households, & Housing Need (rounded): January 1, 2013-October 31, 2021 (8.8 years) 1 Population: October 31, 2021 (SACOG's Projection) 2,713,330 2 less: Group Quarters Population (SACOG's estimate) -57,210 3 Household (HH) Population 2,656,120 Household Formation Groups HH PopulationHH Formation Households or Headship Age Groups (DOF) 2,656,120Rate (ACS) 1,058,740 Under 15 502,318 - - 15 - 24 years 337,782 14.31% 48,330 25 - 34 years 360,451 46.00% 165,800 35 - 44 years 325,195 53.02% 172,420 45 - 54 years 327,870 56.43% 185,020 55 - 64 years 343,922 58.14% 199,950 65 and older 458,581 62.63% 287,220 4 Projected Households 1,058,740 5 less: Households at Beginning of Projection Period (January 1, 2013 interpolated) -941,110 6 Household Growth: 8.8 Year Projection Period (New Housing Unit Need) 117,630 7 Vacancy Allowance Owner Renter Total Tenure Percentage 60.73% 39.27% HH Growth (New Unit Need) 71,440 46,190 117,630 Vacancy Rate (SACOG) 1.50% 5.00% Vacancy Allowance 1,070 2,310 3,380 3,380 8 Replacement Allowance (minimum) 0.50% 121,010 610 9 less: Adjustment for Absorption of Existing Excess Vacant Units Effective Healthy Estimate 80% Absorbed, 20% Not Absorbed by 2013 Vacant Units Market Units Differential Derived (2010 Census, Vacancy Rates) (42,110) 25,430 -16,680 Total Exisitng (2011) Housing Stock 42,110 Existing Vacant Unit (Others) Adjustment 1.72% 1.49% Total Adjusted Existing Vacant Units (Others) (16,100) 13,940 -2,160 Estimated Units (Others) Not Absorbed by 2013 20% -18,840 -3,770 FINAL REGIONAL HOUSING NEED DETERMINATION (High Range of New Housing Unit Need) 117,850

Explanation and Data Sources 1 Population : Pursuant to Government Code Section 65584.01(b), SACOG’s 2021 population projection was compared to the 2021 population derived from Department of Finance (DOF) 2011 Interim Projections published in June 2011 for 2020 and DOF’s E5 estimate for 2011. Based on SACOG’s population projection being within 3% of the DOF Population Interim projections and consultation with SACOG, SACOG’s population projection was used in determining housing need for the region. 2 Group Quarter Population : Figure is SACOG's estimate of persons residing either in a group home, institution, military, or dormitory using the DOF 2010 E5 estimates for 2010, and maintaining its proportion in the total population constant throughout the projection period. As this population doesn't constitute a "household" population generating demand for a housing unit, the group quarter population is excluded from the calculation of the household population, and is not included in the housing need.

3 Household (HH) Population : The portion of population projected to reside in housing units after subtracting the group quarter population from total projected population. ATTACHMENT 3

HCD REGIONAL HOUSING NEED DETERMINATION (HIGH RANGE): SACOG

4 Projected 2021 Households (HHs) : Projected 2020 HHs are derived by applying (to 2020 HH population) the regional 2005-2009 American Community Survey (ACS) household formation rates as provided by DOF. HH formation or headship rates reflect the propensity of different population groups (age, racial and ethnic) to form households. For October 2021, the household number and its distribution by age group were estimated based on the 2020 projections. 5 Households at Beginning of Projection Period : For the first time since inception of RHNA, the baseline number of households at the beginning of the projection period (January 2013) must be projected, as a direct effect of amendment to Section 65588(e)(6) specifying the new projection period to start on either June 30 or December 31 whichever date most closely precedes the end of the current housing element period (June 30, 2013 for SACOG). As such, the 2013 household number was calculated as an interpolation between SACOG’s baseline 2008 number of households and its 2020 projected number of households.

6 Household (HH) Growth : This figure reflects projected HH growth and need for new units.

7 Vacancy Allowance : An allowance (unit increase) is made to facilitate availability and mobility among owner and renter units. Owner/Renter % is based on Census 2010 data. A smaller rate is applied to owner units due to less frequent mobility than for renter households. Information from a variety of authoritative sources supports an acceptable range of 1 to 4% for owner units and 4 to 8% for renter units depending on market conditions. 8 Replacement Allowance : Rate (0.5%) reflects the housing losses that localities annually reported to DOF each January for years 2000-2010, or 0.5%, whichever is higher.

9 Adjustment for Absorption of Existing Excess Vacant Units : For this RHNA cycle only (due to extraordinary uncertainty regarding conditions impacting the economy and housing market not expected to similarly impact future RHNA cycles), a new one-time adjustment was made to account for unprecedented high vacancies in existing stock due to unusual conditions including high foreclosures and recession uncertainties. A fast absorption rate of 80% of existing excess vacant units is assumed to occur in shrinking current excess vacant units before start of 2013 RHNA projection period resulting in applying a 20% adjustment to account for units not absorbed that decreases new housing need by -3,770 units. Existing housing stock consists of two components: (1) housing units for sale and rent in existing housing stock that are above the housing units required to maintain the healthy market condition, calculated as the number of units in housing stock (for sale+for rent+sold, not occupied+rented, not occupied + occupied units), (2) housing units in the "vacant units others" category of existing housing stock above the simple average of 1.49% calculated based on Census data from 1990 to 2010. To evaluate the reasonableness of vacancy adjustments proposed by SACOG to account for the unprecedented economic downturn, the Department used 2010 Census Demographic profile data (DP-1) and desirable "normal" vacancy rates by tenure, in conjunction with the region's household growth and proposed household formation rates. The proposed vacancy adjustment is limited to not exceed the differential between the 2010 Census vacant units and the healthy market vacant units rate associated with the region's annual household growth. As the adjustment was below the differential, the adjustment was applied in calculating the high RHNA range.

APPENDIX 2A

Five Draft Methodologies: Narrative Description of Draft Methodologies

Sacramento Area Council of Governments (SACOG)

2013‐2021 Regional Housing Needs Allocation (RHNA)

60‐DAY PUBLIC COMMENT DRAFT PROPOSED METHODOLOGIES

(Approved for Release on September 15, 2011)

This document describes five Regional Housing Needs Allocation (RHNA) methodologies the SACOG Board of Directors approved for public comment review. This document provides a summary of the RHNA process and the creation of the methodologies. For a more detailed explanation of the process and frequently asked questions, visit the RHNA webpage: www.sacog.org/rhnp.

Written public comments will be accepted by SACOG through Monday, November 14, 2011. Comments received will be included as part of the packet submitted to the SACOG Board of Directors for review. The Board is anticipated to approve one of these methodologies with or without alteration at its December 15, 2011 meeting.

Comments may be submitted to: Greg Chew, SACOG Senior Planner, 1415 L Street, Suite 300, Sacramento, CA 95814, or via email at [email protected] Again, comments must be received no later than Monday, November 14, 2011.

RHNA Background: Every eight years, the State of California, through the Housing and Community Development Department (HCD), issues a Regional Housing Needs Determination to SACOG’s six‐county region. The regional determination includes an overall housing need number, as well as a breakdown of the number of units required in four income distribution categories for the next eight year planning period. This RHNA period covers January 1, 2013 to October 31, 2021. SACOG worked with HCD to develop a draft RHNA earlier than required by law to ensure coordination between the MTP/SCS projections and the RHNA projection. Although SACOG had not received its official letter of determination at the time of the Board’s action to release these methodologies, HCD informed SACOG in mid‐June 2011 that its overall RHNA is in a range starting at 105,000 units during the planning period. Of this amount, 41,830 or 39.838% of the units must be affordable. These figures are subject to change until SACOG receives the official letter of determination from HCD.

Based on the regional determination provided by HCD, SACOG must develop a Regional Housing Needs Allocation (RHNA) and a Regional Housing Needs Plan (RHNP). After the RHNA and RHNP are adopted by the SACOG Board, local jurisdictions are required to update their housing elements to reflect the RHNA. State housing element law (Gov. Code Sections 65580 et seq.), requires each local jurisdiction to show how its housing element intends to zone enough overall units during the RHNA period. It must also show how it will zone enough higher density units and/or deed‐restricted units, or take other steps, to meet the allocation of affordable units.

Creating and adopting a methodology for distributing the regional determination to each jurisdiction in the region is the basis for the RHNA. The methodology, ultimately adopted by the SACOG Board, must be a formula for distributing the number of housing units in each jurisdiction in the six‐county Sacramento region (El Dorado, Placer, Sacramento, Sutter, Yolo, and Yuba counties) and must provide capacity for during the RHNA period. Unlike in other SACOG processes, the RHNA includes the Tahoe Basin in El Dorado and Placer counties. The adopted methodology must be consistent with objectives of the state housing element law, which requires all jurisdictions to provide a mix of housing types for a diverse income range, and to avoid the overconcentration of affordable income populations. In addition, SB 375 (Chapter 728, Statutes of 2008) requires that the RHNA methodology be consistent with the land use pattern in the region’s Sustainable Communities Strategy (SCS).

The methodology will provide each of the cities and counties in the region with two allocations: (1) an overall housing unit allocation for the RHNA planning period; and (2) a sub‐allocation for each of the four income categories defined by state law (and defined below). The sub‐ allocations for the four income categories add up to the total overall allocation. The two lowest, the Very Low Income and Low Income categories, are considered the “affordable categories.” For purposes of this memorandum, SACOG combines the calculations of the Very Low and Low Income categories and refers to them as the “affordable allocation.”

Public Process for the RHNA Methodology: Public comments must be received by SACOG within 60 days of release. Following the 60‐day public comment period, the SACOG Board may make any revisions to the proposed methodology that are deemed appropriate in response to public comments, and then adopt a final methodology. The Board is anticipated to select, possibly modify and approve a methodology at its December 15, 2011 meeting. After the final methodology is adopted, it will be applied to the official RHNA once it is provided by HCD. In early 2012, the SACOG Board will review the official draft allocation for the jurisdictions in the region. However, for the benefit of the Board and stakeholders, SACOG staff is releasing preliminary draft allocations associated with each methodology.

Key Terms Explained

‐ Region: for RHNA purposes, SACOG includes El Dorado, Placer, Sacramento, Sutter, Yolo and Yuba counties, including the Tahoe Basin in El Dorado and Placer counties.

SACOG Regional Housing Needs Allocation (RHNA) Page 2 Draft Proposed Methodologies for Public Comment ‐ Income Categories: state housing element law defines four income categories: very low, low, moderate, and above moderate. Each is defined by comparing median family income (MFI) to a household with the same number of members in the same county. “Very low” income households have incomes 50 percent or lower than MFI. “Low” income households have incomes between 50 percent and 80 percent of MFI. “Moderate” income households have incomes between 80 percent and 120 percent of MFI. “Above moderate” income households have incomes greater than 120 percent MFI.

‐ Affordable Income Categories: very low and low income categories combined.

‐ Regional Average of Affordable Housing Units: percentage of housing units in the region that fall into the affordable income categories. This number is expected to be 39.838% according to HCD, which uses the five‐year 2005‐2009 American Community Survey data.

‐ Affordable Base: the calculation of affordable units each jurisdiction starts with. It is 39.838% of a jurisdiction’s overall allocation, which is the percentage of affordable income households in the region.

‐ Non‐Affordable Base: the calculation of moderate and above moderate income units each jurisdiction starts with. It is 60.162% of a jurisdiction’s overall allocation (100% minus 39.838%), which is the combined percentage of moderate and above moderate‐ income households in the region.

‐ Adjustment Factor: a calculated number that adjusts allocations based on the objective the factor seeks to address. For instance, the income adjustment factor compares the percent share a jurisdiction has of affordable income housing units versus the regional average. The jobs‐housing ratio adjustment factor compares each jurisdiction’s jobs/housing ratio for projected growth between 2008‐35 to the regional jobs/housing ratio of projected growth during that same time. The transit service area adjustment factor is the percent of a jurisdiction’s projected housing unit growth between 2008‐35 that is within transit priority areas (e.g., a half‐mile radius of a major transit stop or high quality transit corridor).

SACOG Regional Housing Needs Allocation (RHNA) Page 3 Draft Proposed Methodologies for Public Comment ‐ Variance: the numerical difference between a jurisdiction and the regional average for the three measured characteristics (jobs/housing ratio, transit service area, and income). The variance is either multiplied by the “affordable base”, “non‐affordable base” or the 2050 Income Trendline to determine an adjustment factor.

‐ CHAS – Comprehensive Housing Affordable Strategy data provided by the U.S. Housing and Urban Development Department. This is a special tabulation of Census data from the US Census Bureau geared towards housing planners and policy makers. The primary purpose of the CHAS data is to demonstrate the number of households in need of housing assistance. One way in which they do this is to provide the number of households by household size that fall within 30, 50 and 80 percent of local median income. This data differs from traditionally available Census data that depicts household income without accounting for household size. For more information please visit: http://www.huduser.org/portal/datasets/cp/CHAS/bg_chas.html.

Process of Methodology Development

Metropolitan Transportation Plan/Sustainable Communities Strategy: The starting point for all four proposed methodologies is the Draft Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS). In June 2011, the SACOG Board endorsed the 2035 Draft Preferred Scenario for use in analyzing and completing the MTP/SCS, which includes a jurisdiction‐level land use allocation for housing and employment growth and a proposed transportation project list. The 2035 Draft Preferred Scenario land use assumptions are reflective of ongoing coordination with local agency planning staff, extensive data collection, alternatives analysis, public involvement, and Board direction. After completing the 2035 Draft Preferred Scenario, staff began work on a 2020 Draft Preferred Scenario that begins with the 2035 Draft Preferred Scenario and works backwards to a reasonable estimate of housing and employment growth, and transportation projects, by 2020, based on the total regional growth forecasted for the region between 2008 and 2020.

In creating the land use assumptions for the MTP/SCS, staff considered the location, type, and amount of development in the region. In developing the growth pattern, staff considered local policies and plans, state and federal regulations (on such issues as flood or habitat constraints), and market and economic conditions. The result is a land use pattern that reflects the Blueprint smart growth principles and is a reasonable assumption for development. The transportation

SACOG Regional Housing Needs Allocation (RHNA) Page 4 Draft Proposed Methodologies for Public Comment investments pair with the land use assumptions of projected development, resulting in transportation and air quality benefits such as fewer vehicle miles traveled, reductions in passenger vehicle greenhouse gas emissions, greater access and mobility, and increases in transit, walking, and biking.

The funding available for transportation projects in the region in this MTP cycle is $5 billion less than in the last MTP due largely to lower population growth rates and the long‐term effects of the recent recession. As a result, the amount of money dedicated to transit, although increased in share in this MTP, is still considerably less in absolute numbers than what was assumed in the last MTP. This makes it very important for SACOG to maximize the benefit of these funds. New transit investment is focused on areas of the region where housing growth is planned at transit‐ supportive densities (medium and high densities). New transit in the MTP/SCS also focuses on connecting to job centers, around which new housing is also being planned. The outcomes of this include a reduction in vehicle miles traveled and greenhouse gas emissions, an increase in “farebox recovery” (the ability for fares to pay for the full operating cost of transit), increased transportation mobility for a greater number of people, and, most importantly from a RHNA perspective, new high‐quality transit service to existing concentrations of low‐income residents. This increases overall affordability, when the costs of housing and transportation are considered together. Locating housing near jobs centers, services near low‐income communities, and non‐auto transportation alternatives to low‐income communities are important social equity considerations included in the MTP/SCS land use pattern and growth assumptions.

In preparation for developing the MTP/SCS 2020 Draft Preferred Scenario, SACOG staff met with each jurisdiction at countywide meetings to discuss the state‐mandated factors that must be considered in developing the RHNA. All of the information provided to SACOG in the RHNA factors meetings was considered in the development of the 2020 Draft Preferred Scenario. Those RHNA‐specific factors are summarized below as:

‐ Existing and projected jobs and housing relationship;

‐ Opportunities and constraints to development of additional housing, including:

. Lack of capacity for sewer and water due to federal or state laws, regulations or regulatory actions, or supply and distribution decisions made by a sewer or water service provider that preclude the jurisdiction from providing necessary infrastructure for additional development during the planning period;

. Availability of land suitable for urban development or for conversion to residential use, the availability of underutilized land, and opportunities for

SACOG Regional Housing Needs Allocation (RHNA) Page 5 Draft Proposed Methodologies for Public Comment infill development and increased residential densities (SACOG may not limit its consideration based on the jurisdiction’s existing zoning ordinances and land use restrictions);

. 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;

. County policies to preserve prime agriculture lands within an unincorporated area;

. Distribution of household growth assumed for a comparable period in the regional transportation plan and opportunities to maximize the use of public transportation and existing transportation infrastructure;

‐ Market demand for housing;

‐ Agreements between a county and cities in the county to direct growth toward incorporated areas of the county;

‐ Loss of units contained in assisted housing developments;

‐ High housing cost burdens;

‐ Housing needs of farmworkers;

‐ Housing needs generated by the presence of a private university or a campus of the California State University or the University of California; and

‐ Any other relevant factors, as determined by SACOG.

Since the information relating to many of these factors was similar for all jurisdictions due to the recent recession (e.g., decreased market demand for housing of all types), SACOG focused on information that was unique to each jurisdiction. For example, a proposed development without some or all of the necessary infrastructure is not unique, as most new developments require infrastructure investments. Therefore, all proposed developments without all necessary infrastructure are compared against other developments in the same submarket in determining the new housing absorption rate by 2020. However, a proposed development located in a floodplain that is lacking the levee improvements needed to allow development is a unique factor that would affect the absorption rate of the housing growth for that individual development in the MTP/SCS 2020 Draft Preferred Scenario.

SACOG Regional Housing Needs Allocation (RHNA) Page 6 Draft Proposed Methodologies for Public Comment Regional Housing Needs Allocation Methodology: After receiving the draft Regional Housing Needs Determination from HCD, SACOG staff distributed two potential methodologies (described later as Methodologies A and B) and corresponding draft allocations to the SACOG Planners Committee. The Planners Committee is comprised of local government planning staffs, housing advocates, and other interested parties from the region. The two additional draft methodologies proposed here (described later as Methodologies D and F) reflect many of the comments from the Planners Committee. Not all ideas discussed could be converted into a methodology due to lack of available data.

Two additional methodologies were proposed from non‐SACOG staff. At the August 23, 2011 Planners Committee, one participant proposed a Methodology E, which the SACOG Board choose not to release for public review. At the September 1, 2011 Land Use and Air Quality Committee meeting, public comment proposed a new methodology, described as Methodology C below.

The use of incentives, such as priority for funding or other incentives, for local governments that are willing to accept a higher share than proposed in the draft allocation was briefly discussed at the Planners Committee. However, because the methodologies are still under consideration at this time, no further discussions on incentives have been conducted.

For further background on the RHNA process, visit the RHNA webpage at http://www.sacog.org/rhnp/rhna.cfm.

Proposed Methodologies ‐ Summary

The SACOG Board of Directors at its September 15, 2011 meeting approved releasing five potential methodologies (Methodologies A, B, C D and F) for public release and comment; Methodology E) was not approved for release and is therefore not included in this document. The five publicly released methodologies begin with the same total allocation for each jurisdiction. Each jurisdiction receives the same percentage of the region’s draft RHND (105,000 units) as assumed in the MTP/SCS 2020 Draft Preferred Scenario. This is referred to as the “overall allocation” in each methodology. The difference in the methodologies is only in how they allocate the affordable units; each emphasizes or addresses different planning policy objectives. They are summarized in the remainder of this document.

Methodology A

Summary: This is the methodology SACOG used for the 2006‐13 RHNA. The methodology creates a trendline for each jurisdiction to determine what percent of new growth must be

SACOG Regional Housing Needs Allocation (RHNA) Page 7 Draft Proposed Methodologies for Public Comment affordable in that jurisdiction in order for all jurisdictions to meet the regional average of affordable housing units by 2050. In other words, those jurisdictions that currently have a higher proportion of affordable housing units, when compared to the current regional average, would receive a lower proportional share of affordable units compared to the average. Conversely, jurisdictions that currently have a lower share of affordable units, when compared to the regional average, would receive a higher percentage of affordable units.

How It Works: This method determines the allocation of affordable units by drawing an “income trendline” from 2008 to 2050, referred to as the “2050 income trendline.” On one endpoint, the 2006‐2008 Census American Community Survey (ACS) shows the percentage of households that a jurisdiction has in each of the four income categories as of 2008. The other endpoint, 2050, shows the projected regional average percentage of households in each income category as determined by HCD; again, the affordable income categories are 39.838 percent. The 2050 income trendline is drawn connecting these two points – the jurisdiction’s current affordable income percentage share of affordable income housing units in 2008 to the 39.838 percent of its housing units in 2050. This line is then intersected at October 31, 2021, the end period for this RHNA cycle. The point of intersection is the percentage of growth that the jurisdiction would need of new affordable housing units to be trending toward the regional average of affordable housing units by 2050. This percentage (see Column C in Table 1) is multiplied by the jurisdiction’s overall allocation (Column A) to determine the jurisdiction’s affordable income allocation (Column B). The resulting formula is:

affordable allocation = overall allocation * 2050 income trendline

Note: this method places a 4 percent floor and 30 percent ceiling in both low and very low income categories (or a total floor of 8% and 60% ceiling for total affordable units) – these floor and ceiling limits were used during the 2006‐13 RHNA cycle.

Analysis: The methodology used in 2006‐13 was based solely on moving each jurisdiction towards regional income parity in terms of its share of affordable housing. As a result, this methodology does not consider the planning principles or other social equity factors built into the land use and transportation assumptions of the MTP/SCS in its affordable allocation. One potential disadvantage to using this methodology with the new MTP/SCS land use and transportation assumptions would be locating existing and future lower income residents away from jobs, services, and transit.

SACOG Regional Housing Needs Allocation (RHNA) Page 8 Draft Proposed Methodologies for Public Comment Methodology B

Summary: This methodology starts all jurisdictions at a percentage of affordable units equal to the percentage of existing affordable income households in the region. It then applies an adjustment factor based on regional income distribution disparities. Similar to the concept in Methodology A, the adjustment factor adds future affordable units to jurisdictions that currently have lower than the regional average and subtracts future affordable units from jurisdictions that have higher than the regional average. This methodology moves all jurisdictions towards achieving the regional average, but rather than every jurisdiction achieving regional parity by 2050, each jurisdiction will reach the regional average at different points in time.

How It Works: It uses a two‐step process. Step 1 establishes the “affordable base” number. Step 2 applies an adjustment factor to move household income distributions toward regional equity. In other words:

overall allocation*regional average of affordable units = affordable base

then,

affordable allocation = affordable base +/‐ income adjustment

Step 1 distributes evenly the regional percentage of affordable units to each jurisdiction. The affordable income category adds up to 39.838 percent for the region, as determined by HCD. In this methodology, every jurisdiction’s “base” or “affordable base” number is calculated by multiplying 39.838 percent by the jurisdiction’s overall allocation number (See Table 2; Column A multiplied by Column C).

Step 2 is a two‐part process (2a and 2b) to adjust the affordable base allocation by a factor that addresses regional income parity. In other words, the adjustment factor trends all jurisdictions towards the regional average of affordable housing units (39.838%).

Step 2a is exactly the same methodology used in Methodology A (see above). Using the “2050 income trendline,” the result of Step 2a shows the percentage of growth that the jurisdiction would need of new affordable housing units to be trending toward the regional average of affordable housing units by 2050.

SACOG Regional Housing Needs Allocation (RHNA) Page 9 Draft Proposed Methodologies for Public Comment percent, means that jurisdiction has a higher percentage share of affordable units than the regional average and, therefore, to get to regional income parity in 2050, it would need less than the regional average between now and 2050. Such a jurisdiction would receive a negative income adjustment factor number (Column F). Conversely, a jurisdiction with a lower share of affordable units when compared to the regional average, would receive a higher percentage than the regional average between now and 2050. Note that Step 2a also places a 4 percent floor and 30 percent ceiling (or “guardrails”) in low and very low‐income categories, as described in Methodology A.

Step 2b subtracts the calculated result in Step 2a (Column D) from 39.838 percent. The difference (Column E), expressed as a percent, is the “variance” from the regional average of affordable housing units. The variance is multiplied by the affordable base number (Column E times Column B), and the product is the “income adjustment factor” (Column F). The adjustment factor is then added or subtracted to the affordable base (remember that an adjustment factor can be negative). The resulting number (Column G) is the number of affordable units allocated for that jurisdiction. Column H shows the percentage of each jurisdiction’s percentage of affordable units compared to its overall allocation.

Although Methodology B differs from the previous methodology, steps 2a and 2b incorporate the same concept used in Methodology A, the 2006‐2013 RHNA methodology.

Analysis: This is the SACOG staff’s preferred methodology. It focuses on the regional land use pattern and where transportation infrastructure investments will be made. Locating jobs and services near low‐income communities and providing non‐auto transportation alternatives to these areas is an important social equity consideration that is included in the MTP/SCS land use pattern and growth assumptions. One way to ensure consistency between the MTP/SCS and RHNA is to keep the land use assumptions of the MTP/SCS intact as the starting point for not just the overall allocation, but for the affordable allocation as well. Draft Methodology B equally distributes the number of affordable income units to each jurisdiction, thereby preserving the distribution of housing growth among jurisdictions. To balance this goal with another state housing law objective to avoid over‐concentrating affordable income housing, draft Methodology B then applies an adjustment factor to the affordable incomes units in each jurisdiction. The adjustment factor is based on the methodology from the 2006‐13 RHNA methodology, which aims to move all jurisdictions towards regional income parity in terms of their share of affordable housing units. One potential disadvantage to this methodology is that it changes the rate by which jurisdictions achieve regional income parity.

SACOG Regional Housing Needs Allocation (RHNA) Page 10 Draft Proposed Methodologies for Public Comment Methodology C

Summary: This methodology addresses two specific factors in the land use pattern of the MTP/SCS – jobs/housing ratio and transit priority areas – in addition to income distribution.

This methodology uniformly starts all jurisdictions with the number of affordable units from the 2050 income trendline allocation described in Methodology A. However, this methodology uses three adjustment factors to add or subtract from the base affordable allocation. The three factors are based on a jurisdiction’s variance from a regional average condition for the following three planning factors: (a) the ratio of growth of jobs to housing units (jobs‐housing balance) between 2008‐2035 ; (b) the percentage of housing unit growth within a transit priority area (transit proximity) between 2008‐2035; and (c) the current regional share of affordable income households (income equity). Each jurisdiction’s current metric for each of these three factors is compared to the regional average. The difference (expressed as a percentage) is divided in half and then each is multiplied by the 2050 income trendline allocation. These three adjustment factors are either added to or subtracted from the base allocation for each jurisdiction.

How It Works: This methodology is summarized in a multi‐step process as follows:

affordable allocation =

2050 income trendline base

+/‐ adjustment #1 (income equity)

+/‐ adjustment #2 (jobs/housing ratio)

+/‐ adjustment #3 (transit proximity)

where “2050 income trendline base” = overall allocation * 2050 income trendline

The “income equity adjustment” examines the regional income disparities by comparing the percentage share each jurisdiction has of very low + low income households to the regional average. Column E shows information from CHAS (through the US Housing and Urban Development Department ‐ HUD) on the percentage share of these households in each jurisdiction as of 2008 (the latest available data). The regional average is 39.838 percent, and is subtracted from Column E to determine the difference (Column F). The difference is divided in half (Column F divided by 2), and the result is Column G, which is multiplied by the “2050 income trendline base” (Column D). The product is Column H, which is the “income adjustment factor.”

The “jobs/housing ratio adjustment” compares each jurisdiction’s current ratio of jobs to housing to the regional jobs/housing average. Column J shows SACOG’s estimated

SACOG Regional Housing Needs Allocation (RHNA) Page 11 Draft Proposed Methodologies for Public Comment jobs/housing ratio for each jurisdiction’s growth in the MTP/SCS. The regional average, 1.2, is subtracted from Column J to determine the difference (Column K). The difference is divided in half (Column K divided by 2), and the result is Column L, which is multiplied by the “2050 income trendline base” (Column D). The product is Column M, which is the “jobs/housing adjustment factor.”

The “transit service area” is the percent of projected housing unit growth a jurisdiction has in a transit priority area in the MTP/SCS by 2035 compared to the regional average for this measure. Column O shows SACOG’s estimated new housing growth between 2008 and 2035 within each jurisdiction that will be in a transit priority area. The regional average, 38 percent, is subtracted from Column O to determine the difference (Column P). The difference is divided in half (Column P divided by 2), and the result is Column Q, which is multiplied by the “2050 income trendline base” (Column D). The product is Column R, which is the “jobs/housing adjustment factor”.

After all three adjustment factors have been calculated, the 2050 income trendline base and the three factors are added together (Columns D + Column H + Column M + Column R) to determine the affordable allocation for each jurisdiction (Column U). Column V shows the allocation as adjusted to fit the exact allocation of affordable units determined by HCD.

Analysis: In Draft Methodology C, each jurisdiction receives a base allocation derived from the 2050 income trendline, which seeks to trend all jurisdictions to have the same proportion of low and very low income housing units by 2050. This methodology then makes adjustments for factors addressed in the MTP/SCS – jobs/housing ratio and transit service – plus the state housing element law – income distribution. The household income factor strengthens the effect of the 2050 trendline, in which jurisdictions with fewer low income units get higher shares and conversely jurisdictions with higher than average low income units get lower shares.

The data used for jobs/housing ratio and transit service is derived directly from the MTP/SCS land use pattern combined with projected transportation and transit investments. Each jurisdiction’s allocation is adjusted according to how far it is from the regional average.

This methodology places affordable housing where there is a higher proportion of jobs and in areas where transit service exists or is planned for, while also shifting affordable housing to communities that have a lower proportion of them. One potential disadvantage to this methodology is an over‐weighting of the MTP/SCS land use pattern and the 2050 income trendline. This methodology will add more units to jurisdictions starting with a high base allocation and remove units from jurisdictions with a low base allocation, essentially diminishing the impact that the MTP/SCS land use assumptions will have on the affordable income unit allocation.

SACOG Regional Housing Needs Allocation (RHNA) Page 12 Draft Proposed Methodologies for Public Comment

Methodology D

Summary: This methodology is a variation of Methodology B. The difference is that this methodology makes the adjustment factor for income inequities more pronounced than in Methodology B. Similar to Methodology B, the “affordable base” is the starting point of affordable units, which is 39.8 percent of the overall allocation for all jurisdictions. In Method B, the adjustment factor is created by determining the variance between percentage of affordable units versus the regional average, and then multiplying that by the “affordable base” (as opposed to multiplying by the overall allocation as in Methodology B). In this variation, Methodology D multiplies the variance by the “non‐affordable” base, which is 60.2 percent of the overall allocation (100% ‐ 39.8% = 60.2%, or the percentage of region’s moderate and above moderate income units). The outcome is that jurisdictions that currently have a smaller percentage share of low‐income housing than the regional average would receive an increased allocation of affordable units that is more pronounced than in Methodology B. Conversely, jurisdictions currently with a higher share of affordable units than the regional average would receive a more pronounced lower share.

How It Works: Everything is the same as Methodology B, from its intent to the mathematical steps to derive the allocation, except one variation, which can be summarized as:

affordable allocation = affordable base + [income variation * non‐affordable base]

In Methodology B, the “affordable base” is the starting point of affordable units, which is 39.838 percent of the overall allocation for all jurisdictions (Table 4, Column A times 39.838%). As in Methodology B, Methodology D creates a “2050 income trendline” (see Methodology A above for description) which is shown in Column D. Column D subtracts the regional average of 39.838 percent to determine the variance, Column E. This is consistent with Methodology B.

Methodology D differs when it multiplies Column E times the “non‐affordable base,” which are the number of units that are not considered low or very low income. Because the regional average and the “affordable base” for all jurisdictions is 39.838 percent, then the “non‐ affordable base” is 60.162 percent of each jurisdictions overall allocation (Column A multiplied by 60.162). The result is Column F, which becomes the “non‐affordable adjustment factor.” It is then added to the “affordable base,” or Column F plus Column C equals the affordable allocation (Column G). Column H shows the percent of each jurisdiction’s overall allocation that would be affordable.

Analysis: Methodology D has a more pronounced adjustment factor for adjusting for income disparities than Methodology B, but otherwise the advantages and disadvantages are the same

SACOG Regional Housing Needs Allocation (RHNA) Page 13 Draft Proposed Methodologies for Public Comment as those in Methodology B.

Methodology E

Methodology E was not approved for public release by the SACOG Board. Its associated allocation chart, Table 5, is not included in this document.

Methodology F

Summary: Note: Methodology F was originally presented as “Methodology C” to the three board committees and the Planners Committee in September

This methodology addresses two specific factors in the land use pattern of the MTP/SCS – jobs/housing ratio and transit priority areas – in addition to income distribution.

Like Methodology B, this methodology uniformly starts all jurisdictions with the same regional percentage of overall units as the “affordable base” allocation. However, this methodology uses three adjustment factors to add or subtract from the base affordable allocation. The three factors are based on a jurisdiction’s variance from a regional average condition for the following three planning factors: (a) the ratio of jobs to housing units (jobs‐housing balance); (b) the percentage of housing units within a transit priority area (transit proximity); and (c) the current regional share of affordable income households (income equity). Each jurisdiction’s current metric for each of these three factors is compared to the regional average. The difference (expressed as a percentage) is divided in half and then each is multiplied by the base allocation. These three adjustment factors are either added to or subtracted from the base allocation for each jurisdiction.

How It Works: This methodology starts with the same first step by distributing the same “affordable base” described in Methodology B (that is, every jurisdiction starts with 39.838 percent of its overall allocation as affordable). However, this methodology differs in that Step 2 has three adjustment factors, not one (as in Methodology B). Step 2 is to apply the adjustment factors to address regional equity for the affordable income allocations. Or, in other words:

overall allocation*regional average of affordable units = affordable base

then,

affordable allocation = affordable base +/‐ adjustment #1 +/‐ adjustment #2 +/‐ adjustment #3

where adjustment #1 is income equity, adjustment #2 is jobs/housing balance, and adjustment #3 is transit proximity.

SACOG Regional Housing Needs Allocation (RHNA) Page 14 Draft Proposed Methodologies for Public Comment The “income adjustment” examines the regional income disparities by comparing the percentage share each jurisdiction has of very low and low income households to the regional average. In Table 6, Column E shows information from CHAS (through the US Housing and Urban Development Department ‐ HUD) on the percentage share of these households in each jurisdiction as of 2008 (the latest available data). The regional average is 39.838 percent, and is subtracted from Column E to determine the difference (Column F). The difference is divided in half (Column F divided by 2), and the result is Column G, which is multiplied by the “affordable base” (Column D). The product is Column H, which is the “income adjustment factor.”

The “jobs/housing ratio adjustment” compares each jurisdiction’s current ratio of jobs to housing to the regional jobs/housing average. Column J shows SACOG’s estimated 2035 jobs/housing ratio for each jurisdiction’s growth in the MTP/SCS. The regional average, 1.2, is subtracted from Column J to determine the difference (Column K). The difference is divided in half (Column K divided by 2), and the result is Column L, which is multiplied by the “affordable base” (Column D). The product is Column M, which is the “jobs/housing adjustment factor.”

The “transit service area” is the percent of projected housing unit growth a jurisdiction has in a transit priority area in the MTP/SCS by 2035 compared to the regional average for this measure. Column O shows SACOG’s estimated new housing growth between 2008 and 2035 within each jurisdiction that will be in a transit priority area. The regional average, 38 percent, is subtracted from Column O to determine the difference (Column P). The difference is divided in half (Column P divided by 2), and the result is Column Q, which is multiplied by the “affordable base” (Column D). The product is Column R, which is the “jobs/housing adjustment factor”.

After all three adjustment factors have been calculated, the affordable base and the three factors are added together (Columns D + Column H + Column M + Column R) to determine the affordable allocation for each jurisdiction (Column U). Column V shows the allocation as adjusted to fit the exact allocation of affordable units determined by HCD.

Analysis: In Draft Methodology F, each jurisdiction receives the same affordable base allocation as the region, then adjustments are made for factors addressed in the MTP/SCS – jobs/housing ratio and transit service – plus the State Housing Element Law – income distribution. The data used in this method is derived directly from the MTP/SCS land use pattern combined with projected transportation and transit investments. Each jurisdiction’s allocation is adjusted according to how far it is from the regional average. This methodology places affordable housing where there is a higher proportion of jobs and in areas where transit service exists or is planned for, while also shifting affordable housing to communities that have a lower proportion of them. One potential disadvantage to this methodology is an over‐weighting of the MTP/SCS land use pattern. By starting with an affordable base allocation that is consistent with the MTP/SCS and then making further adjustments for MTP/SCS factors, this methodology will add

SACOG Regional Housing Needs Allocation (RHNA) Page 15 Draft Proposed Methodologies for Public Comment more units to jurisdictions starting with a high base allocation and remove units from jurisdictions with a low base allocation, essentially increasing the impact that the MTP/SCS land use assumptions will have on the affordable income unit allocation.

SACOG Regional Housing Needs Allocation (RHNA) Page 16 Draft Proposed Methodologies for Public Comment

APPENDIX 2B

Five Draft Methodologies: Associated Allocations of Draft Methodologies

Table 1: Methodology A ‐ Using 2006‐13 Methodology Applied to 2013‐21 RHNA Cycle DISCUSSION DRAFT FOR September 15, 2011 SACOG Board Meeting ‐ action is NOT being taken on these alloc RHNA Period : January 1, 2013 through October 31, 2021 . Applying 2006‐13 RHNA Methodology to 2013‐21 RHNA Cycle Total Projected Growth Very Low + Low Income Allocation (Jan 1, (Jan 1, 2013‐October 31, 2013‐ Oct 31, 2021) 2021)

2013‐21 RHNA ‐ Total number of Units Number of Very Low Percent of total units (based on proportion of + Low units (Col A * that are Very Low + Low MTP/SCS 2020 projection) Col C)

ABC

Placerville 372 109 29.3% South Lake Tahoe1 336 28 8.3% El Dorado Uninc Tahoe Basin1 480 277 57.6% El Dorado Uninc 3,949 1,702 43.1% El Dorado County total 5,137 2,115 41.2%

Auburn 308 131 42.4% Colfax 51 12 23.1% Lincoln 3,791 1,794 47.3% Loomis 154 73 47.1% Rocklin 3,814 2,152 56.4% Roseville 8,480 4,595 54.2% Placer Uninc Tahoe Basin1 328 189 57.5% Placer Uninc 4,704 2,622 55.7% Placer County total 21,630 11,567 53.5%

Citrus Heights 696 203 29.2% Elk Grove 7,404 4,248 57.4% Folsom 4,634 2,420 52.2% Galt 679 150 22.1% Isleton 23 4 19.4% Rancho Cordova 7,010 2,361 33.7% Sacramento 24,108 6,635 27.5% Sacramento Uninc 13,848 5,132 37.1% Sacramento County total 58,402 21,154 36.2%

Live Oak 449 172 38.3% Yuba City 2,680 1,055 39.4% Sutter Uninc 335 162 48.2% Sutter County total 3,464 1,389 40.1%

Davis 1,066 419 39.3% West Sacramento 5,978 2,031 34.0% Winters 320 134 42.0% Woodland 1,878 538 28.7% Yolo Uninc 1,891 687 36.3% Yolo County total 11,133 3,810 34.2%

Marysville 72 6 8.1% Wheatland 484 173 35.9% Yuba Uninc 4,678 1,616 34.5% Yuba County total 5,234 1,795 34.3%

SUM 105,000 41,830 39.8%

Sacramento Area Council of Governments 1 ‐ Tahoe Basin allocations based on projections provided by the Tahoe Regional Planning Agency Table 2: Methodology B ‐ 2013‐21 RHNA Allocation Using Draft Staff Proposal DICUSSION DRAFT for September 15, 2011 Board Meeting ‐ action is NOT being taken on these allocations RHNA Period: January 1, 2013 through October 31, 2021

DRAFT PROPOSED METHODOLOGY B (Jan 1, 2013 to Oct 31, 2021 RHNA Cycle) Overall Base Number: Equal Share Very Low+Low Income Adjustment Factor: Regional Equity Allocation for all Jurisdictions Alloctions

Targeted % of Base units Total number of allocation for Base distributed in Income Allocation VL + Units (based on Allocation VL + Very Allocation VL+L by Variance from Adjust Factor L by Percent of proportion of L units (Col B + Low+Low Very Low + October 31, (Col D‐ (Col B*Col E) Total (Col MTP/SCS 2020 Col F) 2021 for 39.838%) G/Col A) projection) (Col A * Col Low % C) regional parity by 2050 ABCDEFGH x=39.838% Placerville 372 148 39.8% 29.3% ‐10.5% ‐16 133 35.7% South Lake Tahoe1 336 134 39.8% 8.3% ‐31.5% ‐42 92 27.3% El Dorado Uninc Tahoe Basin1 480 191 39.8% 57.6% 17.8% 34 225 46.9% El Dorado Uninc 3,949 1,573 39.8% 43.1% 3.3% 51 1,624 41.1% El Dorado County total 5,137 2,046 39.8% 41.2% 2,074

Auburn 308 123 39.8% 42.4% 2.6% 3 126 40.9% Colfax 51 20 39.8% 23.1% ‐16.7% ‐3 17 33.2% Lincoln 3,791 1,510 39.8% 47.3% 7.5% 113 1,623 42.8% Loomis 154 61 39.8% 47.1% 7.3% 4 66 42.7% Rocklin 3,814 1,519 39.8% 56.4% 16.6% 252 1,772 46.4% Roseville 8,480 3,378 39.8% 54.2% 14.3% 485 3,863 45.6% Placer Uninc Tahoe Basin1 328 131 39.8% 57.5% 17.7% 23 154 46.9% Placer Uninc 4,704 1,874 39.8% 55.7% 15.9% 298 2,172 46.2% Placer County total 21,630 8,617 39.8% 53.5% 9,792

Citrus Heights 696 277 39.8% 29.2% ‐10.6% ‐29 248 35.6% Elk Grove 7,404 2,950 39.8% 57.4% 17.5% 517 3,467 46.8% Folsom 4,634 1,846 39.8% 52.2% 12.4% 229 2,075 44.8% Galt 679 271 39.8% 22.1% ‐17.8% ‐48 222 32.8% Isleton 23 9 39.8% 19.4% ‐20.5% ‐2 7 31.7% Rancho Cordova 7,010 2,793 39.8% 33.7% ‐6.2% ‐172 2,621 37.4% Sacramento 24,108 9,604 39.8% 27.5% ‐12.3% ‐1,183 8,421 34.9% Sacramento Uninc 13,848 5,517 39.8% 37.1% ‐2.8% ‐153 5,364 38.7% Sacramento County total 58,402 23,266 39.8% 36.2% 22,425

Live Oak 449 179 39.8% 38.3% ‐1.5% ‐3 176 39.2% Yuba City 2,680 1,068 39.8% 39.4% ‐0.5% ‐5 1,063 39.7% Sutter Uninc 335 134 39.8% 48.2% 8.4% 11 145 43.2% Sutter County total 3,464 1,380 39.8% 40.1% 1,384

Davis 1,066 425 39.8% 39.3% ‐0.5% ‐2 423 39.6% West Sacramento 5,978 2,382 39.8% 34.0% ‐5.9% ‐140 2,242 37.5% Winters 320 127 39.8% 42.0% 2.2% 3 130 40.7% Woodland 1,878 748 39.8% 28.7% ‐11.2% ‐84 665 35.4% Yolo Uninc 1,891 753 39.8% 36.3% ‐3.5% ‐26 727 38.4% Yolo County total 11,133 4,435 39.8% 34.2% 4,186

Marysville 72 29 39.8% 8.1% ‐31.7% ‐9 20 27.2% Wheatland 484 193 39.8% 35.9% ‐4.0% ‐8 185 38.3% Yuba Uninc 4,678 1,864 39.8% 34.5% ‐5.3% ‐99 1,765 37.7% Yuba County total 5,234 2,085 39.8% 34.3% 1,969

SUM 105,000 41,830 39.8% 39.8% 0 41,830 39.8%

Sacramento Area Council of Governments 1 ‐ Tahoe Basin allocations based on projections provided by the Tahoe Regional Planning Agency Table 3: Methodology C ‐ Three Adjustment Factors with 2050 Trendline Affordable Base DISCUSSION DRAFT FOR September 15, 2011 SACOG Board Meeting ‐ action is NOT being taken on these allocations RHNA Period : January 1, 2013 through October 31, 2021 Adjustment Factor A: INCOME Adjustment Factor B: Jobs/Housing Balance Adjustment Factor C: Proximity to Transit A+B+C VL+L VL+L VL+L Method C Method C Method C Overall 2050 Income % Households Variance Half of Adjustme Jobs/ Variance Half of Adjustme % of 2008‐ Variance Half of Adjustme Factors A, 2050 Adjusted to Adjusted to Allocation 2013‐ Trend Line in VL + L from Variance nt Factor Housing Ratio from 1.2 Variance nt Factor 2035 Growth from 38% Variance nt Factor B and C Trendline match HCD match HCD 2021 Base Allocation (CHAS data) 39.838% (Col F * *2050 2008‐2035 J/H Ratio (Col K* * 2050 within TPA Ave (Col C ‐ (Col P * *2050 combined Affordable Target = Target = Very (see Table 1, 50%) Trendline Growth Average 50%) Trendline (SACOG 38%) 50%) Trendline BASE + 3 Very Low + Low + Low Col B) Afford (SACOG data) (Col J ‐ 1.2) Afford. data) Afford Adjust Low Allocation % Base (Col Base (Col Base (Col Factors Allocation G*Col D) L * Col D) D * Col Q)

C D EFGHJKLMOPQ RTUVW REGIONAL GOAL x=39.838% region ave = 1.2 region ave=38% Placerville 372 109 46.5% ‐6.7% ‐3.4% ‐4 0.7 ‐0.5 ‐25.0% ‐27 0.0% ‐38.0% ‐19.0% ‐21 ‐52 57 60 16.1% South Lake Tahoe1 336 28 51.3% ‐11.4% ‐5.7% ‐2 unknown 0 unknown 0 ‐2 26 29 8.5% El Dorado Uninc Tahoe Basin1 480 277 26.8% 13.1% 6.5% 18 unknown 0 unknown 0 18 295 298 62.1% El Dorado Uninc 3,949 1,702 26.8% 13.1% 6.5% 111 1.4 0.2 10.0% 170 0.0% ‐38.0% ‐19.0% ‐323 ‐42 1,660 1,687 42.7% El Dorado County total 5,137 2,115 32.1% 0.0% 124

Auburn 308 131 37.6% 2.2% 1.1% 1 0.7 ‐0.5 ‐25.0% ‐33 9.0% ‐29.0% ‐14.5% ‐19 ‐50 80 83 26.8% Colfax 51 12 52.5% ‐12.6% ‐6.3% ‐1 3.7 2.5 125.0% 15 0.0% ‐38.0% ‐19.0% ‐2 12 24 24 46.8% Lincoln 3,791 1,794 33.7% 6.1% 3.1% 55 0.9 ‐0.3 ‐15.0% ‐269 0.0% ‐38.0% ‐19.0% ‐341 ‐555 1,239 1,265 33.4% Loomis 154 73 32.1% 7.7% 3.9% 3 1.0 ‐0.2 ‐10.0% ‐7 0.0% ‐38.0% ‐19.0% ‐14 ‐18 54 55 35.9% Rocklin 3,814 2,152 30.2% 9.6% 4.8% 104 1.4 0.2 10.0% 215 14.0% ‐24.0% ‐12.0% ‐258 61 2,213 2,239 58.7% Roseville 8,480 4,595 29.5% 10.3% 5.2% 238 1.6 0.4 20.0% 919 9.0% ‐29.0% ‐14.5% ‐666 490 5,085 5,144 60.7% Placer Uninc Tahoe Basin1 328 189 31.1% 8.7% 4.4% 8 unknown 0 unknown 0.0% 0 8 197 199 60.7% Placer Uninc 4,704 2,622 31.1% 8.7% 4.4% 114 1.0 ‐0.2 ‐10.0% ‐262 0.0 ‐38.0% ‐19.0% ‐498 ‐646 1,976 2,009 42.7% Placer County total 21,630 11,567 31.2% 0.0% 523

Citrus Heights 696 203 42.2% ‐2.4% ‐1.2% ‐2 1.2 0.0 0.0% 0 64.0% 26.0% 13.0% 26 24 227 232 33.4% Elk Grove 7,404 4,248 26.1% 13.7% 6.9% 292 1.1 ‐0.1 ‐5.0% ‐212 0.0% ‐38.0% ‐19.0% ‐807 ‐728 3,520 3,571 48.2% Folsom 4,634 2,420 23.3% 16.5% 8.3% 200 1.3 0.1 5.0% 121 7.0% ‐31.0% ‐15.5% ‐375 ‐54 2,366 2,398 51.7% Galt 679 150 46.1% ‐6.3% ‐3.1% ‐5 1.0 ‐0.2 ‐10.0% ‐15 0.0% ‐38.0% ‐19.0% ‐28 ‐48 102 106 15.7% Isleton 23 4 54.7% ‐14.8% ‐7.4% 0 0.5 ‐0.7 ‐35.0% ‐2 0.0% ‐38.0% ‐19.0% ‐1 ‐3 2 2 8.2% Rancho Cordova 7,010 2,361 47.8% ‐8.0% ‐4.0% ‐94 1.0 ‐0.2 ‐10.0% ‐236 31.0% ‐7.0% ‐3.5% ‐83 ‐413 1,948 1,996 28.5% Sacramento 24,108 6,635 47.7% ‐7.9% ‐3.9% ‐261 1.1 ‐0.1 ‐5.0% ‐332 75.0% 37.0% 18.5% 1,227 635 7,270 7,435 30.8% Sacramento Uninc 13,848 5,132 41.9% ‐2.1% ‐1.0% ‐53 1.3 0.1 5.0% 257 57.0% 19.0% 9.5% 488 691 5,824 5,919 42.7% Sacramento County total 58,402 21,154 42.0% 0.0% 77

Live Oak 449 172 39.1% 0.7% 0.3% 1 0.6 ‐0.6 ‐30.0% ‐52 0.0% ‐38.0% ‐19.0% ‐33 ‐84 88 92 20.4% Yuba City 2,680 1,055 39.3% 0.5% 0.3% 3 1.3 0.1 5.0% 53 0.0% ‐38.0% ‐19.0% ‐200 ‐145 910 929 34.7% Sutter Uninc 335 162 30.6% 9.3% 4.6% 7 0.6 ‐0.6 ‐30.0% ‐48 0.0% ‐38.0% ‐19.0% ‐31 ‐72 90 92 27.5% Sutter County total 3,464 1,389 37.5% 0.0% 11

Davis 1,066 419 37.5% 2.3% 1.2% 5 1.1 ‐0.1 ‐5.0% ‐21 80.0% 42.0% 21.0% 88 72 491 499 46.8% West Sacramento 5,978 2,031 45.6% ‐5.8% ‐2.9% ‐59 1.2 0.0 0.0% 0 82.0% 44.0% 22.0% 447 388 2,419 2,460 41.1% Winters 320 134 34.3% 5.5% 2.8% 4 1.1 ‐0.1 ‐5.0% ‐7 0.0% ‐38.0% ‐19.0% ‐26 ‐29 106 108 33.8% Woodland 1,878 538 44.4% ‐4.6% ‐2.3% ‐12 1.4 0.2 10.0% 54 0.0% ‐38.0% ‐19.0% ‐102 ‐61 478 490 26.1% Yolo Uninc 1,891 687 41.9% ‐2.0% ‐1.0% ‐7 1.9 0.7 35.0% 240 77.0% 39.0% 19.5% 134 367 1,054 1,067 56.4% Yolo County total 11,133 3,810 41.7% 0.0% ‐69

Marysville 72 6 45.2% ‐5.3% ‐2.7% 0 2.2 1.0 50.0% 3 0.0% ‐38.0% ‐19.0% ‐1 2 8 8 11.2% Wheatland 484 173 40.9% ‐1.1% ‐0.5% ‐1 0.8 ‐0.4 ‐20.0% ‐35 0.0% ‐38.0% ‐19.0% ‐33 ‐69 105 108 22.4% Yuba Uninc 4,678 1,616 43.9% ‐4.1% ‐2.0% ‐33 1.1 ‐0.1 ‐5.0% ‐81 0.0% ‐38.0% ‐19.0% ‐307 ‐421 1,195 1,227 26.2% Yuba County total 5,234 1,795 44.0% 0.0% ‐34

105,000 41,830 631 408 38% ‐1,759 41,110 41,830 39.8% ‐720 Sacramento Area Council of Governments 1 ‐ Tahoe Basin allocations based on projections provided by the Tahoe Regional Planning Agency Table 4 ‐ Methdology D: 2013‐21 RHNA Allocation Using Methodology B Variation DISCUSSION DRAFT FOR September 15, 2011 SACOG Board Meeting ‐ action is NOT being taken on these allocations RHNA Period : January 1, 2013 through October 31, 2021

METHODOLOGY D (Jan 1, 2013 to Oct 31, 2021 RHNA Cycle) Overall Base Number: Equal Share for all Very Low+Low Income Adjustment Factor: Regional Equity Allocation Jurisdictions Alloctions

Affordable Targeted % of Non‐ units Adjustment Allocation VL + Total number of Base Affordable Affordable distributed in Income Factor L ‐ Base + Allocation VL + Units (based on allocation for Base Base = VL+L by Variance from (Mod+Above (Variance * L by Percent of proportion of Very Allocation Moderate + October 31, (Col D‐ Mod)*Varianc Mod+Above Total (Col G/Col MTP/SCS 2020 Low+Low Very Low + Above Mod 2021 for 39.838%) e (Col C2*Col Mod units) A) projection) (Col A * Col Low % (Col A ‐ Col B) regional parity E) (Col B + Col F) C) by 2050 A B C1 C2 D E F G H x=39.838% Placerville 372 148 39.8% 224 29.3% ‐10.5% ‐23 125 33.5% South Lake Tahoe1 336 134 39.8% 202 8.3% ‐31.5% ‐64 70 20.9% El Dorado Uninc Tahoe Basin1 480 191 39.8% 289 57.6% 17.8% 51 243 50.5% El Dorado Uninc 3,949 1,573 39.8% 2,376 43.1% 3.3% 77 1,651 41.8% El Dorado County total 5,137 2,046 39.8% 41.2% 2,088

Auburn 308 123 39.8% 185 42.4% 2.6% 5 127 41.4% Colfax 51 20 39.8% 31 23.1% ‐16.7% ‐5 15 29.8% Lincoln 3,791 1,510 39.8% 2,281 47.3% 7.5% 171 1,681 44.3% Loomis 154 61 39.8% 93 47.1% 7.3% 7 68 44.2% Rocklin 3,814 1,519 39.8% 2,295 56.4% 16.6% 381 1,900 49.8% Roseville 8,480 3,378 39.8% 5,102 54.2% 14.3% 732 4,110 48.5% Placer Uninc Tahoe Basin1 328 131 39.8% 197 57.5% 17.7% 35 166 50.5% Placer Uninc 4,704 1,874 39.8% 2,830 55.7% 15.9% 450 2,324 49.4% Placer County total 21,630 8,617 39.8% 53.5% 10,392

Citrus Heights 696 277 39.8% 419 29.2% ‐10.6% ‐44 233 33.5% Elk Grove 7,404 2,950 39.8% 4,454 57.4% 17.5% 781 3,731 50.4% Folsom 4,634 1,846 39.8% 2,788 52.2% 12.4% 345 2,191 47.3% Galt 679 271 39.8% 408 22.1% ‐17.8% ‐73 198 29.1% Isleton 23 9 39.8% 14 19.4% ‐20.5% ‐3 6 27.5% Rancho Cordova 7,010 2,793 39.8% 4,217 33.7% ‐6.2% ‐260 2,533 36.1% Sacramento 24,108 9,604 39.8% 14,504 27.5% ‐12.3% ‐1,786 7,818 32.4% Sacramento Uninc 13,848 5,517 39.8% 8,331 37.1% ‐2.8% ‐231 5,285 38.2% Sacramento County total 58,402 23,266 39.8% 36.2% 21,996

Live Oak 449 179 39.8% 270 38.3% ‐1.5% ‐4 175 38.9% Yuba City 2,680 1,068 39.8% 1,612 39.4% ‐0.5% ‐7 1,060 39.6% Sutter Uninc 335 134 39.8% 202 48.2% 8.4% 17 150 44.9% Sutter County total 3,464 1,380 39.8% 40.1% 1,385

Davis 1,066 425 39.8% 641 39.3% ‐0.5% ‐3 422 39.5% West Sacramento 5,978 2,382 39.8% 3,597 34.0% ‐5.9% ‐211 2,170 36.3% Winters 320 127 39.8% 192 42.0% 2.2% 4 132 41.2% Woodland 1,878 748 39.8% 1,130 28.7% ‐11.2% ‐126 622 33.1% Yolo Uninc 1,891 753 39.8% 1,138 36.3% ‐3.5% ‐40 713 37.7% Yolo County total 11,133 4,435 39.8% 34.2% 4,059

Marysville 72 29 39.8% 43 8.1% ‐31.7% ‐14 15 20.8% Wheatland 484 193 39.8% 291 35.9% ‐4.0% ‐12 181 37.5% Yuba Uninc 4,678 1,864 39.8% 2,814 34.5% ‐5.3% ‐149 1,714 36.6% Yuba County total 5,234 2,085 39.8% 34.3% 1,911

SUM 105,000 41,830 39.8% 63,170 39.8% 0 41,830 39.8%

Sacramento Area Council of Governments 1 ‐ Tahoe Basin allocations based on projections provided by the Tahoe Regional Planning Agency Table 5: Methodology E: Same Proportional Allocation to All Jurisdictions DICUSSION DRAFT for September 15, 2011 Board Meeting Action is NOT being taken on these allocations RHNA Period: January 1, 2013 through October 31, 2021

All Jurisdictions Received 39.838% Low and Very Low Income Base Number: Equal Share for all Overall Allocation Jurisdictions

Total number of Units Low and Very Low (based on proportion of Regional Very Low + Income Allocation MTP/SCS 2020 Low % projection) (Col B * Col C) ABC

Placerville 372 39.8% 148 South Lake Tahoe1 336 39.8% 134 El Dorado Uninc Tahoe Basin1 480 39.8% 191 El Dorado Uninc 3,949 39.8% 1,573 El Dorado County total 5,137 39.8% 2,046

Auburn 308 39.8% 123 Colfax 51 39.8% 20 Lincoln 3,791 39.8% 1,510 Loomis 154 39.8% 61 Rocklin 3,814 39.8% 1,519 Roseville 8,480 39.8% 3,378 Placer Uninc Tahoe Basin1 328 39.8% 131 Placer Uninc 4,704 39.8% 1,874 Placer County total 21,630 39.8% 8,617

Citrus Heights 696 39.8% 277 Elk Grove 7,404 39.8% 2,950 Folsom 4,634 39.8% 1,846 Galt 679 39.8% 271 Isleton 23 39.8% 9 Rancho Cordova 7,010 39.8% 2,793 Sacramento 24,108 39.8% 9,604 Sacramento Uninc 13,848 39.8% 5,517 Sacramento County total 58,402 39.8% 23,266

Live Oak 449 39.8% 179 Yuba City 2,680 39.8% 1,068 Sutter Uninc 335 39.8% 134 Sutter County total 3,464 39.8% 1,380

Davis 1,066 39.8% 425 West Sacramento 5,978 39.8% 2,382 Winters 320 39.8% 127 Woodland 1,878 39.8% 748 Yolo Uninc 1,891 39.8% 753 Yolo County total 11,133 39.8% 4,435

Marysville 72 39.8% 29 Wheatland 484 39.8% 193 Yuba Uninc 4,678 39.8% 1,864 Yuba County total 5,234 39.8% 2,085

SUM 105,000 39.8% 41,830

Sacramento Area Council of Governments 1 ‐ Tahoe Basin allocations based on projections provided by the Tahoe Regional Planning Agency Table 6: Methodology F ‐ Three Adjustment Factors and Base Affordable Allocation DISCUSSION DRAFT FOR September 15, 2011 SACOG Board Meeting ‐ action is NOT being taken on these allocations RHNA Period : January 1, 2013 through October 31, 2021 Adjustment Factor A: INCOME Adjustment Factor B: Jobs/Housing Balance Adjustment Factor C: Proximity to Transit A+B+C VL+L VL+L VL+L Method C Method F Method F Overall Base Affordable % Households Variance Half of Adjustme Jobs/ Housing Variance Half of Adjustme % of 2008‐ Variance Half of Adjustme Factors A, BASE + 3 Adjusted to Adjusted to Allocation 2013‐ Allocation ‐ in VL + L from Variance nt Factor * Ratio 2008‐ from 1.2 Variance nt Factor * 2035 Growth from 38% Variance nt Factor * B and C Adjust match HCD match HCD 2021 VL+L (Col (CHAS data) 39.838% (Col F * VL+V (Col 2035 Growth J/H Ratio (Col K* VL+V (Col within TPA Ave (Col C ‐ (Col P * VL+V (Col combined Factors Target = Very Target = Very C*39.838%) 50%) G*Col D) (SACOG data) Average 50%) L * Col D) (SACOG data) 38%) 50%) D * Col Q) Low + Low Low + Low (Col J ‐ 1.2) Allocation Allocation %

CDEFGHJKLMOPQRTUVW REGIONAL AVERAGES x=39.838% x=39.838% region ave = 1.2 region ave=38% Placerville 372 148 46.5% ‐6.7% ‐3.4% ‐5 0.7 ‐0.5 ‐25.0% ‐37 0.0% ‐38.0% ‐19.0% ‐28 ‐70 78 78 21.0% South Lake Tahoe1 336 134 51.3% ‐11.4% ‐5.7% ‐8 unknown 0 unknown 0 ‐8 126 126 37.5% El Dorado Uninc Tahoe Basin1 480 191 26.8% 13.1% 6.5% 12 unknown 0 unknown 0 12 204 204 42.5% El Dorado Uninc 3,949 1,573 26.8% 13.1% 6.5% 103 1.4 0.2 10.0% 157 0.0% ‐38.0% ‐19.0% ‐299 ‐39 1,534 1,539 39.0% El Dorado County total 5,137 32.1% 0.0% 103

Auburn 308 123 37.6% 2.2% 1.1% 1 0.7 ‐0.5 ‐25.0% ‐31 9.0% ‐29.0% ‐14.5% ‐18 ‐47 76 76 24.7% Colfax 51 20 52.5% ‐12.6% ‐6.3% ‐1 3.7 2.5 125.0% 25 0.0% ‐38.0% ‐19.0% ‐4 20 41 41 80.4% Lincoln 3,791 1,510 33.7% 6.1% 3.1% 46 0.9 ‐0.3 ‐15.0% ‐227 0.0% ‐38.0% ‐19.0% ‐287 ‐467 1,043 1,046 27.6% Loomis 154 61 32.1% 7.7% 3.9% 2 1.0 ‐0.2 ‐10.0% ‐6 0.0% ‐38.0% ‐19.0% ‐12 ‐15 46 46 29.9% Rocklin 3,814 1,519 30.2% 9.6% 4.8% 73 1.4 0.2 10.0% 152 14.0% ‐24.0% ‐12.0% ‐182 43 1,562 1,567 41.1% Roseville 8,480 3,378 29.5% 10.3% 5.2% 175 1.6 0.4 20.0% 676 9.0% ‐29.0% ‐14.5% ‐490 360 3,739 3,750 44.2% Placer Uninc Tahoe Basin1 328 131 31.1% 8.7% 4.4% 6 unknown 0 unknown 0.0% 0 6 136 137 41.8% Placer Uninc 4,704 1,874 31.1% 8.7% 4.4% 82 1.0 ‐0.2 ‐10.0% ‐187 0.0 ‐38.0% ‐19.0% ‐356 ‐462 1,412 1,416 30.1% Placer County total 21,630 31.2% 0.0% 384

Citrus Heights 696 277 42.2% ‐2.4% ‐1.2% ‐3 1.2 0.0 0.0% 0 64.0% 26.0% 13.0% 36 33 310 311 44.7% Elk Grove 7,404 2,950 26.1% 13.7% 6.9% 203 1.1 ‐0.1 ‐5.0% ‐147 0.0% ‐38.0% ‐19.0% ‐560 ‐505 2,444 2,452 33.1% Folsom 4,634 1,846 23.3% 16.5% 8.3% 153 1.3 0.1 5.0% 92 7.0% ‐31.0% ‐15.5% ‐286 ‐41 1,805 1,810 39.1% Galt 679 271 46.1% ‐6.3% ‐3.1% ‐8 1.0 ‐0.2 ‐10.0% ‐27 0.0% ‐38.0% ‐19.0% ‐51 ‐87 184 184 27.1% Isleton 23 9 54.7% ‐14.8% ‐7.4% ‐1 0.5 ‐0.7 ‐35.0% ‐3 0.0% ‐38.0% ‐19.0% ‐2 ‐6 4 4 17.4% Rancho Cordova 7,010 2,793 47.8% ‐8.0% ‐4.0% ‐111 1.0 ‐0.2 ‐10.0% ‐279 31.0% ‐7.0% ‐3.5% ‐98 ‐488 2,304 2,311 33.0% Sacramento 24,108 9,604 47.7% ‐7.9% ‐3.9% ‐378 1.1 ‐0.1 ‐5.0% ‐480 75.0% 37.0% 18.5% 1,777 919 10,523 10,555 43.8% Sacramento Uninc 13,848 5,517 41.9% ‐2.1% ‐1.0% ‐57 1.3 0.1 5.0% 276 57.0% 19.0% 9.5% 524 743 6,260 6,279 45.3% Sacramento County total 58,402 42.0% 0.0% ‐203

Live Oak 449 179 39.1% 0.7% 0.3% 1 0.6 ‐0.6 ‐30.0% ‐54 0.0% ‐38.0% ‐19.0% ‐34 ‐87 92 92 20.5% Yuba City 2,680 1,068 39.3% 0.5% 0.3% 3 1.3 0.1 5.0% 53 0.0% ‐38.0% ‐19.0% ‐203 ‐147 921 924 34.5% Sutter Uninc 335 133 30.6% 9.3% 4.6% 6 0.6 ‐0.6 ‐30.0% ‐40 0.0% ‐38.0% ‐19.0% ‐25 ‐59 74 75 22.4% Sutter County total 3,464 37.5% 0.0% 10

Davis 1,066 425 37.5% 2.3% 1.2% 5 1.1 ‐0.1 ‐5.0% ‐21 80.0% 42.0% 21.0% 89 73 498 499 46.8% West Sacramento 5,978 2,382 45.6% ‐5.8% ‐2.9% ‐69 1.2 0.0 0.0% 0 82.0% 44.0% 22.0% 524 455 2,837 2,845 47.6% Winters 320 127 34.3% 5.5% 2.8% 4 1.1 ‐0.1 ‐5.0% ‐6 0.0% ‐38.0% ‐19.0% ‐24 ‐27 100 101 31.6% Woodland 1,878 748 44.4% ‐4.6% ‐2.3% ‐17 1.4 0.2 10.0% 75 0.0% ‐38.0% ‐19.0% ‐142 ‐84 664 665 35.4% Yolo Uninc 1,891 753 41.9% ‐2.0% ‐1.0% ‐8 1.9 0.7 35.0% 264 77.0% 39.0% 19.5% 147 403 1,156 1,160 61.3% Yolo County total 11,133 41.7% 0.0% ‐85

Marysville 72 29 45.2% ‐5.3% ‐2.7% ‐1 2.2 1.0 50.0% 14 0.0% ‐38.0% ‐19.0% ‐5 8 37 37 51.4% Wheatland 484 193 40.9% ‐1.1% ‐0.5% ‐1 0.8 ‐0.4 ‐20.0% ‐39 0.0% ‐38.0% ‐19.0% ‐37 ‐76 117 117 24.2% Yuba Uninc 4,678 1,864 43.9% ‐4.1% ‐2.0% ‐38 1.1 ‐0.1 ‐5.0% ‐93 0.0% ‐38.0% ‐19.0% ‐354 ‐485 1,379 1,383 29.6% Yuba County total 5,234 44.0% 0.0% ‐40

105,000 41,830 169 107 38% ‐401 41,705 41,830 39.8% ‐125 Sacramento Area Council of Governments 1 ‐ Tahoe Basin allocations based on projections provided by the Tahoe Regional Planning Agency

APPENDIX 2C

Five Draft Methodologies: Comment Letters on Draft Methodologies

APPENDIX 2D:

Five Draft Methodologies: SACOG Responses to Comments Regarding Draft Allocations

FAQ on Comments Letters on

Five Draft Methodologies for Regional Housing Needs Allocation (RHNA)

(Draft November 21, 2011)

SACOG received 18 letters during the 60‐day public comment period regarding the draft methodologies for the Regional Housing Needs Allocation (RHNA). This document responds to the issues and/or questions raised in the letters. Copies of all comment letters and this FAQ will be provided to the SACOG Board of Directors and its three committees. One of those committees, the Land Use & Air Quality Committee, will make a recommendation to the SACOG Board of Directors on which of the five methodologies to approve at its December 15, 2011 meeting. For background information about the RHNA process, go to the SACOG website at http://www.sacog.org/rhnp/rhna.cfm . For a description of the five draft methodologies, see the document “60‐Day Public Comment Draft Proposed Methodologies” released on September 15, 2011.

The comments are summarized below. The source of each comment is identified; the complete letters are attached as Attachment D.

Comments/Questions on

General RHNA and Methodology Approaches

Comment #1: Letter 15, city of Rocklin: City staff recommends/requests that the overall number of units assigned to the region be reconsidered and challenged if necessary. The overall number seems overly optimistic given the lack of development that is likely to occur within that time period. The 2006‐ 13 projections were made when the region was experiencing a dramatically different economy and consistently higher pace of development. Yet the new number is not significantly lower (118,652 in 2006‐13, and 105,000 for 2012‐21) and many jurisdictions, particularly some in Placer County, have been assigned almost double their prior overall number of units. All jurisdictions in the region have experienced a significant decrease in residential and non‐residential building activity since the economic downtown in 2007. Economic analysts predict that this trend will ultimately reverse, however the timing of the recovery is an estimate at best, and ranges on average between three and five years from today. These facts were previously supported with documentation in the city’s August 8, 2011, comments to SACOG regarding the Draft 2020 growth projections prepared for the Draft 2035 MTP/SCS Update and should continue to be considered.

Response #1: The overall regional allocation was the result of much collaborative discussion and data‐ sharing with the California Department of Housing and Community Development (HCD), the agency which issues the allocation. While the number may seem high in light of today’s economic situation, the number is, in fact, approximately 25 percent lower per year when compared to the 2006‐13 regional allocation. In addition, the next RHNA period does not start until January 1, 2013 by which time the economy is forecasted to show some recovery. The planning period ends October 31, 2021 and SACOG’s current projections indicate development activity continuing to recover within this time period. It is also important to remember that the transportation projects in the MTP are based on these growth projections. Reductions in growth rates will require corresponding reductions in estimated revenues for the MTP.

One additional consideration to note is that zoned housing units that jurisdictions received “credit” for in the 2006‐13 RHNA cycle, but which have not received building permits, may be counted again in the 2013‐21 RHNA period. Because many jurisdictions with certified housing elements may have only had a relatively small portion of their zoned parcels constructed, these same parcels/units are eligible to be counted in the upcoming RHNA cycle.

Comment/Question #2: Letter #4b, city of Elk Grove: Is the demand for 41,830 high density low‐ income housing units supported by any market studies done by SACOG or other agencies?

Response #2: As noted above, SACOG worked with HCD to develop the lower range of the overall allocation number of 104,970 housing units (the draft amount was 105,000). Once that number was determined, HCD applied the region’s share of the four income categories based on current income distribution of the region’s households. The current low and very‐low income categories comprise 39.8 percent of the total households in the region. HCD therefore allocated the region 39.8 percent of the total number as low (16.4 percent) and very‐low (23.4 percent) income categories for the 2013‐21 RHNA cycle, which adds up to 41,780 units.

Comment #3: Letter #1, city of Live Oak: In many farming‐dependent communities such as Live Oak, average family income levels are not on par with some of the other larger communities and the local housing market reflects that. As such, affordable housing should be shared amongst all SACOG jurisdictions, and affordable housing should be located near job markets and near public transit.

Response #3: SACOG acknowledges that there are disparities in household incomes in communities throughout the region and some rural communities have lower median incomes than more populous urban ones. However, the RHNA allocations by income are accounted for by each county’s median income, not the region’s median income. Therefore, affordability standards in Live Oak are compared to Sutter County’s standards, not the rest of the SACOG region. What is considered affordable in one county may not be in another county. When the region’s allocation was developed by HCD, affordability levels were considered for each individual county.

Four out of the five methodologies (all except Methodology A) address affordable housing near jobs and public transit. The only difference between them is the degree to which these two factors are weighted November 21, 2011 RHNA Response to Written Comments Page 2 in the methodology. Methodology B is the one that staff believes is most reflective of the MTP/SCS. Methodology D places a more pronounced weighting on regional income parity. Methodology F explicitly weights income distribution, proximity to transit, and jobs/housing ratios, while Methodology C takes Methodology F and gives the income factor more weight.

Comment #4: Letter #4b, city of Elk Grove: Has SACOG done any analysis on reconciling the Blueprint goals with the land use patterns effectively created by the RHNA?

Response #4: The Blueprint preferred scenario serves as the basis for the land use pattern in the draft Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS). The adopted MTP/SCS projection for 2008‐2020 is the basis for what SACOG used to determine the overall allocation of housing units for each jurisdiction. From there, the selected methodology will determine how to allocate each of the four income categories.

Comment #5: Letter #4b, city of Elk Grove: The city of Elk Grove would like to see other methodologies further explored including: transportation investment, infrastructure limitations, current housing prices and rents.

Response #5: The RHNA must be consistent with the MTP/SCS, which is the foundation for where the region’s transportation investments will be made through 2035. The limitations in infrastructure are considered in the developing the MTP/SCS. The state Housing Element Law (Government Code section 65584.04(d)) requires that the RHNA consider the lack of sewer or water capacity in a jurisdiction. These factors were considered in the development of the MTP/SCS projections, which directly relate to the overall RHNA. However, current housing prices and rents are not identified factors in the state Housing Element Law that must be considered in the development of the RHNA.

Comment #6: Letter #17, city of Marysville: None of the methodologies take into account the fact that the city of Marysville is physically constrained and does not have the ability to add housing, whether low‐income or market rate. All methodologies start with the premise that the population/housing in Marysville will grow. However, the 2010 Census shows a decrease in population of almost 200 people from the 2000 Census. If Marysville did not see growth during the last housing boom, what set of circumstances could we have in the next cycle that would change that trend? Whichever methodology SACOG selects should be altered to reflect the reality of the last 10 years.

Response #6: The overall allocations were determined through the projections for the MTP/SCS. SACOG developed the draft overall allocation and shared this information for review with each jurisdiction. Every jurisdiction was projected to grow because the region is projected to grow. In

November 21, 2011 RHNA Response to Written Comments Page 3

Marysville’s case, the growth in Yuba County, and the importance of Beale AFB as an employment center, led SACOG to project growth for the city. If no response was given by the jurisdiction, then the draft allocations as developed were forwarded for review to the SACOG Board of Directors, which ultimately approved the overall allocations for the MTP/SCS.

Comment #7 ‐ Letter #8, Placer County: SACOG is not responsible for the allocation of units to Placer County’s Tahoe Basin area, and it is worth noting that 131 allocated high density residential units within the Basin is unachievable.

Response #7: Although the Tahoe Basin area in Placer and El Dorado counties is not part of the SACOG service area, the state of California requires that SACOG provide allocations through the RHNA process for all of Placer and El Dorado counties, including the Tahoe Basin.

Comment #8: Letter #2, city of Sacramento: When it comes to developing a RHNA consistent with the objectives of the state housing element law, proximity to transit and jobs/housing balance cannot take the place of achieving balanced and diverse communities throughout the region. Furthermore, the jobs/housing balance factored into the other proposed methodologies does not account for whether the job pays low wages or not, or whether the housing is affordable or not.

Response #8: The objectives identified in the state Housing Element Law (Government Code section 65584) do not emphasize which is of greater importance: socioeconomic equity, or promoting infill development and protection of the environment and agricultural resources. As such, SACOG staff does not interpret of the state Housing Element Law or SB 375 as making regional parity more important – or less important, for that matter – than smart growth planning principles such as proximity to transit or jobs/housing balance. A significant investment in the MTP/SCS has been made in strategic areas within the region to provide for higher frequency transit and other multi‐modal means. Higher density housing should follow where those public investments go to achieve the objectives of SB 375 and the Housing Element Law. Methodology D would achieve an equitable distribution of balanced communities by income in the region faster than Methodology B. However, moving towards regional parity is not the only public policy objective that SACOG is trying achieve. Balanced planning objectives, such as smart land uses and transportation options, are also important factors. Methodologies B and D are related, but D makes a more pronounced adjustment towards regional parity.

SACOG staff agrees that the jobs/housing balance does not take into account “jobs/housing fit.” This concept considers the types of jobs, and the associated wages, to determine what types of housing are needed to go with them. SACOG is developing a “jobs/housing fit” analysis as part of its federal Sustainable Communities Regional Planning grant work; however, the data and analysis is not ready to be factored into this RHNA cycle.

November 21, 2011 RHNA Response to Written Comments Page 4

Comment #9: Letter #12, Legal Services of Northern California: It appears that each proposed methodology lacks sufficient attention to existing housing need and that while SACOG appears to be trying to be true to the spirit of SB 375, the proposals do not account for the need to have adequate affordable housing, equitably distributed, in all areas, including small, rural and unincorporated areas. The methodology needs to ensure that an affordable housing supply is available to all economic segments of all communities, not only communities that presently have transit hubs or jobs/housing balance. SACOG should ensure this in order to be consistent with applicable laws.

Response #9: SACOG has worked with its local government members, the development community, housing advocates and other stakeholders to develop methodologies that meet the intent of the state Housing Element Law and SB 375. All methodologies are limited by the availability of data, but these methodologies were all developed with the same stated objectives.

Comments/Questions on

Advantages/Disadvantages of the Individual Methodologies

Methodology A

Pros – Methodology A

Comment #10: Letter #13, city of Citrus Heights: The city believes that Methodology A is the most equitable methodology as it aims for regional parity in the number of affordable housing units by 2050. Several methodologies introduce other variables, such as jobs/housing ratio, transit proximity, future transportation investments, etc. In some regards, these other methodologies seem to penalize jurisdictions that have either developed in a compact manner, developed more than their “fair share” of affordable housing, or are planning for their new growth areas to be developed in ways consistent with the Preferred Blueprint Scenario. Because of this, the city believes Methodology A is the most equitable.

Response #10: Methodology A is based solely on moving each jurisdiction towards regional parity in terms of its share of affordable housing and the methodology did not consider the land use pattern and transportation investments in the MTP/SCS in its allocation of low‐ and very‐low income units. SB 375 now requires the RHNA methodology to be consistent with the land use pattern and transportation investments in the draft MTP/SCS. Methodology A does not directly consider smart growth planning principles or any of the other social equity factors built into the land use and transportation assumptions of the MTP/SCS. One potential disadvantage to using this methodology, which was used in the 2006‐13 RHNA cycle would be locating existing and future lower‐income residents away from jobs, services, and transit.

November 21, 2011 RHNA Response to Written Comments Page 5

Comment #11: Letter #16, Sacramento County: Sacramento County finds Methodology A to be fair and reasonable because it results in social equity for low‐income households by avoiding an increase in the percentage of low‐income units in any particular jurisdiction. Those jurisdictions that have an existing higher percentage of low‐income households will receive a lower percentage of affordable units in their allocation. The goal of this methodology is to eventually have every jurisdiction take on its “fair share” of low income units.

Response #11: As discussed in Response #10, this methodology is based solely on trending every jurisdiction towards reaching the same proportion of income distributions by 2050. All other methodologies, except Methodology A, factor in both regional parity and planning principles that are consistent with SB 375.

Cons – Methodology A

Comment #12 – Letter #5, city of Galt: Purely from a “fair share housing” standpoint, Methodology A seems to be the most equitable way to allocate the affordable units as has been done in the past. It takes into account each jurisdiction’s historical track record of providing affordable housing and then allocates the fair share of new affordable housing with the intent of achieving parity by 2050. However, it may not best take into account the required objectives of SB 375 that were built into the MTP/SCS assumptions.

Response #12: Comment noted.

Methodology B

Pros – Methodology B

Comment #13: Letter #4, city of Elk Grove: The city’s understanding of Methodology B is that it attempts to achieve consistency with the MTP/SCS by introducing an adjustment factor that moves each jurisdiction towards regional parity but attempts to factor in the importance of locating low‐income housing near transit and services. This is the city’s second choice of methodologies, behind Methodology F. However, if Methodology B is selected, there is an expectation that SACOG and other funding agencies, such as HCD will reevaluate its expenditure priorities to focus on increasing access to transit and services in the communities that are expected to increase their share of the region’s affordable housing.

November 21, 2011 RHNA Response to Written Comments Page 6

Response #13: The comment regarding the methodology has been noted. The allocation of funding priorities for transit and other transportation‐related services and infrastructure is examined every four years through the MTP process following the direction of the SACOG Board of Directors.

Comment #14: Letter #12, Legal Services of Northern California: An affordable decent place to live (with access to good transportation and employment) is the key to personal and household stability. Thus, it is imperative, and in the interest of the economic health of the entire region, that SACOG’s actions help maximize the opportunities for affordable housing development in a way that promotes regional equity. Of the five methodologies that SACOG has put forward, LSNC believes Methodology B is the most consistent with a regional equity approach in that it has the most potential to counter over‐ concentration and promote inclusion of affordable housing throughout most of the SACOG region. That said, LSNC remains concerned that the methodology may not do enough to promote sufficient affordable housing in small jurisdictions that continue to have unmet need for decent affordable housing.

Response #14: Comments noted. SACOG will continue to work with local governments, the development community and other stakeholders to encourage production of affordable housing, not just plan for it.

Cons – Methodology B

Comment #15: Letter #5, city of Galt: Methodology B results in a higher number of affordable units allocated to small jurisdictions, like Galt and Isleton, than other methodologies. However, cities with high jobs/housing ratios have nearly the lowest percentage of lower income households in their communities as compared to the region. Methodology B allocates nearly the lowest number of units to each of them compared to others.

Response #15: Comment noted.

Comment #16: Letter #16, Sacramento County: The adjustment factor for income inequalities places a higher burden on some jurisdictions. Methodology B begins with an “affordable base” in determining the affordable unit allocations for each jurisdiction. Methodology A does not do this. Sacramento County does not support Methodology B as each jurisdiction will reach the regional average (percentage of units that are affordable) at different points in time. For this reason, this methodology is inherently unfair to jurisdictions that already have a high percentage of low‐income households.

November 21, 2011 RHNA Response to Written Comments Page 7

Response #16: The balance of planning objectives and socioeconomic equality objectives is the challenge in developing the RHNA methodology. SACOG staff believes that Methodology B provides a balance of income considerations coupled with regional planning objectives. Methodology B is consistent with the MTP/SCS, which is required by SB 375. In creating the land use assumptions for the MTP/SCS, staff has considered the location, type, and amount of development in the region. In developing the growth pattern, staff considers local policies and plans, state and federal regulations (such as flood or habitat constraints), and market and economic conditions. The result is a land use pattern that reflects both the Blueprint principles and is a reasonable forecast for development. The transportation investments pair with the land use assumptions and together they result in transportation and air quality benefits such as reductions in vehicle miles traveled and greenhouse gas emissions and increases in transit, walking, and biking.

The funding available for transportation projects in the region in this MTP cycle is $5 billion less than in the last MTP. As a result, the amount of money dedicated to transit, although increased in share in this MTP/SCS, is still considerably less than what was assumed in the last MTP. This makes it very important that SACOG maximize the benefit of these funds. Since transit is most efficient in locations with higher densities, locating more new homes and jobs near transit will maximize the productivity of transit investments. Therefore, the land use pattern assumes a higher proportion of overall growth happening in urban areas where much of the transit investments are planned. The outcomes of this include a reduction in vehicle miles traveled and greenhouse gas emissions, an increase in “farebox recovery” (the ability for fares to cover more of the operating costs of transit), and most importantly from a RHNA perspective, more new high quality transit to existing concentrations of low‐income residents. This increases overall affordability, when the costs of housing plus transportation are considered together. Locating jobs and services near low‐income communities and providing non‐auto transportation alternatives to these areas is an important social equity consideration that is included in the MTP/SCS land use pattern and growth assumptions.

One way to ensure consistency between the MTP/SCS and RHNA is to keep the land use assumptions of the MTP/SCS intact as the starting point for the RHNA total allocation and the very‐low and low‐income unit allocation. To achieve this, Methodology B equally distributes the number of low‐ and very‐low income units to each jurisdiction. However, state Housing Element Law objectives include avoiding over‐concentrating low‐ and very‐low income housing. To adjust for this, draft Methodology B then applies an adjustment factor to the very‐low and low‐income units in each jurisdiction. The adjustment factor is based on the methodology from the 2006‐13 RHNA methodology, which aims to move all jurisdictions towards regional parity in terms of their share of affordable housing by 2050. Draft Methodology B, therefore, reflects the objectives of the MTP/SCS, while providing an adjustment factor for income in an effort to meet the multiple objectives of SB 375 and housing element law.

November 21, 2011 RHNA Response to Written Comments Page 8

Methodology C

Pros – Methodology C

Comment #17: Letter #6, Sutter County: The County prefers Methodology C. Proposals for high density development are typically directed toward the incorporated cities, where public sewer and water are available. Locating high density residential projects within incorporated cities also allows residents of the development to be in closer proximity to jobs as well as existing bus routes. Preservation of agricultural lands is also a primary goal of unincorporated areas.

Response #17: The SACOG staff understands the importance of preserving agricultural lands in the region. Agricultural preservation is one of the objectives in the state Housing Element law (Government Code section 65584). However, a main concern with Methodology C is that it double‐counts socioeconomic factors, as described in Response #19, when compared to the other objectives. The state Housing Element Law does not assign a higher priority for socioeconomic parity than other objectives.

Comment #18: Letter #1, city of Live Oak: The city states its preference for Methodology C or F, because affordable housing should be located near the jobs market and near public transit and should be shared amongst all cities and counties in the region.

Response #18: SACOG staff agrees that affordable housing should be located near jobs, public transit and shared among all jurisdictions. The main concern SACOG staff has with methodologies C and F is that they over‐compensate for those three factors. These methodologies each start with a base allocation from Methodology B (which is directly based on the MTP/SCS land use assumptions) and have already factored in high frequency transit, income distributions and jobs/housing ratio. Methodologies C and F then take each of those three variables and explicitly factor them in again, effectively double weighting them. In the SACOG staff’s opinion, Methodology B better reflects the true nature of what the region is planning for in the MTP/SCS in terms of public transit and jobs‐housing balance in the MTP/SCS while factoring in income disparities.

Cons – Methodology C

Comment #19: Letter #3, city of Roseville, and similar comments in Letter #15, city of Rocklin: Methodology A, D and especially C weight too heavily the social equality factor (parity) in determining high density residential allocations. It is problematic when the primary focus of social parity is not in harmony with transportation links and investments. In addition, this methodology shows a range of 8 to 62 percent high density housing depending on the jurisdiction, which creates extreme winners and losers. All methodologies which show extreme percentages should be rejected as inequitable.

November 21, 2011 RHNA Response to Written Comments Page 9

Response #19: Comment noted. It should be noted, however, that the low‐ and very‐low Income category allocations do not necessarily only equate to high density residential. This category may also include deed restricted housing that is kept affordable. Many non‐profit affordable housing developers use deed restricted housing as part of their conditions of development to ensure low‐ or very‐low income households inhabit the units regardless of who owns the property. Deed restricted units may be of any residential density.

Comment #20: Letter #5, City of Galt: Methodology C expands on the assumption already built into the MTP/SCS. While Galt is not opposed to this methodology, the factor of income variance seems to be double counted. It is addressed in the trend line base allocation and then again in the adjustment factor based on regional average income. While it results in a lower allocation for the City of Galt, it may unfairly affect the allocation of other jurisdictions.

Response #20: Comment noted. SACOG staff agrees that the income variance factor is double weighted with this methodology.

Comment #21: In Letter #4a, City of Elk Grove: The emphasis on regional parity in Methodology C fails to fully account for the wide differences in availability of public transportation and social services, which are disproportionately used and needed by low income populations.

Response #21: Comment noted.

Comment #22: Letter #16, Sacramento County: Transit‐oriented development and improving jobs/housing balance play important roles in Methodologies C and F, and are important goals in the amended Sacramento County General Plan adopted on November 9, 2011. However, to have sustainable development in the region, and also fulfill the objectives of the state Housing Element Law, proximity to transit and jobs/housing balance cannot completely replace balanced and diverse communities. These methodologies disproportionately affect mature communities of unincorporated Sacramento County. Methodologies C and F, in particular, require that jurisdictions with higher transit access and better jobs/housing balance take on a higher percentage of low income units. These methodologies appear to impact the jurisdictions of Sacramento County, and the cities of Sacramento, West Sacramento, and Rancho Cordova. The result could lead to an excess burden of affordable units in these communities while the surrounding communities produce above‐moderate income housing and at the same time are producing significant amounts of low‐wage service jobs.

Response #22: Comment noted. SACOG staff agrees that methodologies C and F double‐weight transit access and jobs/housing balance. They also double‐weight income distribution.

November 21, 2011 RHNA Response to Written Comments Page 10

Methodology D

Pros – Methodology D

Comment #23: Letter #2, city of Sacramento: The city believes Methodology D makes the most sense in achieving an equitable distribution of balanced communities in the region. The jurisdictions with the smaller percentage share of low‐income housing than the regional average would receive an increased allocation of affordable units that is more pronounced than in Methodology B.

Response #23: Comment noted that Methodology D would result in a more pronounced increase in affordable units to jurisdictions with a smaller percentage of low‐income housing.

Comment #24: Letter #5, city of Galt: Methodology D includes a more significant adjustment factor for income by taking the adjustment from the larger non‐affordable base. It seems to be the “middle of the road” methodology that does not affect certain jurisdictions in a disproportionate way. The average of the allocation numbers in all five methodologies, Methodology D looks to be reasonably close to the average in most cases.

Response #24: Comment noted.

Comment #25: Letter #16, Sacramento County: Because of the increased linkage between the Metropolitan Transportation Plan and the implementation of SB 375, Sacramento County supports Methodology D as a means to achieve the development of balanced, diverse and sustainable communities throughout the region. Methodology D combines the best features of methodologies A and B. It places an emphasis on social equity while being consistent with the MTP and SCS. Methodology D will allow jurisdictions that currently have a higher percentage of low‐income units than the regional average to receive a more pronounced lower share of affordable units than in other proposed methodologies, while jurisdictions that currently have a lower percentage of low‐income units will receive a more pronounced increase in affordable units (than in Methodology B).

Response#25: Comment noted.

November 21, 2011 RHNA Response to Written Comments Page 11

Cons – Methodology D

Comment #26: Letter #1, city of Live Oak: Placing a reliance on public transportation, as do Options C and D, makes sense as people in affordable housing often have difficulty traveling great distances to work due to the expense associated with travel. While Live Oak does have very limited public transportation to Yuba City, it is not at a level that would support traveling daily to work. Many of the large communities have existing transit systems that will support the need.

Response #26: Comment noted. All methodologies, except Methodology A, factor in public transportation and jobs/housing balance, although methodologies C and F make these factors more pronounced.

Methodology F

Pros – Methodology F

Comment #27: Letter #7, city of Winters: Some rural communities are struggling to encourage economic development and attract business. The lack of a thriving jobs center leads to an imbalance of jobs per household within a jurisdiction. In addition, some rural communities are not located within the transit priority areas defined by SACOG. All five methodologies attempt to balance the objectives of both state Housing Element Law and SB 375. However, the “apples to oranges” comparison of urban and rural municipalities can only be lessened through Methodology F. The application of the jobs/housing ratio and the proximity to transit adjustment factors places affordable housing where there is a higher proportion of jobs in areas where transit service exists or is planned for, which is consistent with SB 375. As a result, Methodology F helps to equalize the allocation based on the advantages (and disadvantages) of the municipalities’ location and/or urban or rural classification.

Response #27: Comments noted.

Comment #28: Letter #8, Placer County: Methodology F is the superior methodology, in that it largely takes into consideration social parity and regional equity, yet also reflects the region’s Blueprint objectives, the state’s efforts to allocate affordable housing, and to reduce greenhouse gas emissions. This methodology is consistent with SB 375, the state housing element law, the Blueprint, and appropriately allocates growth to existing and future transportation hubs where transportation funds have been dedicated.

Response #28: The main issue that the SACOG staff sees with methodologies C and F are that they double count the transit, jobs/housing ratio and income factors. November 21, 2011 RHNA Response to Written Comments Page 12

Comment #29: Letter #15, city of Rocklin: The city recommends adopting Methodology F, and can accept Methodology B as an alternative. Both methodologies meet state law objectives for allocating affordable housing, and recognize Blueprint objectives and the reduction of greenhouse gas emissions. Further, both provide a cognizant and necessary link between the location of transit and affordable housing.

Response #29 Comment noted.

Comment #30: Letter #9, Teen Center USA ( Elk Grove) and similar comments in Letter #11, Elk Grove Food Bank Services: While the Teen Center USA is not directly involved in creating or providing housing resources, we focus on serving lower‐income Elk Grove households by providing after‐school activities for youth ages 11‐17. The teens served by our programs are typically low‐income youth, and we have found that many of them living in households face severe economic challenges. Our budget is stretched very thin. Since proximity and transit access is a huge factor for teens who do not drive, we would love to expand our locations to serve more areas in Elk Grove, but budget limitations make this impossible for the foreseeable future. We would like to be able to support 3,500 more affordable housing units in Elk Grove, but unfortunately the public and private funding mechanisms have not provided us with sufficient funding to do so. Therefore, we support Methodology F, which we feel is fair given the region’s commitment to funding social services in our community.

Response #30: Comment noted. In the current economic climate, social service budgets throughout all communities in the region are being cut.

Cons – Methodology F

See Comments #19 through #22 for Responses for discussions about Methodology C that also apply to Methodology F.

Comment #31: Letter #8, Placer County and similar comment in Letter #3, city of Roseville: The county recognizes that while the range of high density residential (HDR) allocation under Methodology F is moderate for most jurisdictions within the region, there are some small jurisdictions where a high percentage is allocated. The city of Colfax is allocated 80 percent HDR in this methodology, presumably due to the availability of rail and highway access. However, the wastewater treatment capacity and other limitations within that community would make such an allocation infeasible. In recognizing this aberration, and to take a collective approach to provide affordable housing within all jurisdictional boundaries within Placer County, the county is open to sharing the HDR allocated to Colfax under this methodology.

November 21, 2011 RHNA Response to Written Comments Page 13

Response #31: Transfers of units are allowed under state law (Government Code section 65594.07) if certain conditions are met, including: (1) one or more cities within the county agree to increase its share or their share in an amount equal to the reduction; and (2) the transfer of shares only occurs between a county and cities within that county.

Comment #32: Letter #16, Sacramento County: Transit‐oriented development and improving jobs/housing balance play important roles in methodologies C and F, and are important goals in the amended Sacramento County General Plan adopted on November 9, 2011. However, to have sustainable development in the region, and also fulfill the objectives of the state Housing Element Law, proximity to transit and jobs/housing balance cannot completely replace balanced and diverse communities. These methodologies disproportionately affect mature communities of unincorporated Sacramento County. Methodologies C and F, in particular, require that jurisdictions with higher transit access and better jobs/housing balance take on a higher percentage of low income units. These methodologies appear to impact the jurisdictions of Sacramento County, and the cities of Sacramento, West Sacramento, and Rancho Cordova. The result could lead to an excess burden of affordable units in these communities while the surrounding communities produce above‐moderate income housing and at the same time are producing significant amounts of low‐wage service jobs.

Response #32: All methodologies except Methodology A factor in jobs/housing balance and proximity to transit. Methodologies C and F double weight them, as well as the income distribution factor.

Comments/Questions on

Legislation/Advocacy

Comment #33: Letter #3, city of Roseville, and similar comments in Letter #8, Placer County: The requirement to plan for 30 dwellings per acre, and concentrate over 405 units of that high density growth in the outlying, new growth areas of growing communities is counter to the objectives of SB 375, which seeks to link affordable housing to transportation options in an effort to reduce greenhouse gas emissions. The region should make an effort to amend the state statutes that requires a default density of 30 units per acre as the definition of providing affordable housing. Short of a legislative change, SACOG staff can advocate to HCD on behalf of the whole region by showing the infeasibility of constructing 30 du/ac.

(see Response after Comment #33)

Comment #33: Letter #15, city of Rocklin: The change in default densities from 20 dwelling units per acre to 30 du/acre is of concern to jurisdictions that are less urban in character. This change does not seem to take into account community character or infrastructure limitations and equipment demands (e.g., such as fire trucks, etc.) that would be necessary to serve that density and height of development in a time when municipal budgets and staffing are shrinking, not growing. This would also require that November 21, 2011 RHNA Response to Written Comments Page 14 many existing sites be redesigned to land use densities that would either be vastly out of character with existing adjacent development and/or that other new sites be redesigned from potentially revenue generating land uses and likely remain undeveloped in order for jurisdictions to demonstrate that the availability of adequate sites has been met on paper. These options are extremely undesirable for local agencies struggling to encourage economic development within their communities. Short of a legislative change, SACOG staff can advocate to HCD on behalf of the whole region by showing the infeasibility of constructing 30 du/ac in suburban settings.

Responses #32 and #33: Because the Metropolitan Statistical Area (MSA) for El Dorado, Placer, Sacramento and Yolo counties reached a population above 2 million in recent years, the state Housing Element Law (Government Code section 65583.2) is applied differently in the 2013‐21 RHNA cycle, compared to the previous one. For this upcoming cycle, jurisdictions with populations of at least 25,000 in those four counties have a new “default density” of 30 dwelling units to the acre. In the 2006‐13 RHNA cycle, the default density was 20 du/ac. The “default density” is the minimum density that the jurisdiction can count towards low‐ and very‐low income categories. However, it is a “default” unless the jurisdiction can convince HCD that there is not a market for such densities. HCD has the discretion to lower the minimum density during the housing element review. SACOG staff will seek direction from the Board of Directors if any legislative advocacy should be taken on this issue. Staff has been conveying the concerns to HCD staff raised by SACOG members about this issue.

For communities with new growth areas, the RHNA does not assign where within a jurisdiction the low‐ and very‐low income categories of housing shall go; this remains the authority of the local jurisdiction.

Comment #34: Letter #7, city of Winters: The actual production of affordable housing is not considered in the allocation of housing units to jurisdictions. The purpose of the RHNA is to plan for housing, not to produce housing. The city believes that the disconnect between planning and production should be remedied and the success of building and saving affordable units by cities and counties should be considered by both SACOG and HCD when allocating housing units in the future.

Response #34: SACOG staff agrees that the state Housing Element Law is more about planning than actual production of affordable housing. SACOG has been involved with discussions at the state level regarding this and will continue to work in this area.

Comment #35: Letter #10, Loomis: The town of Loomis is concerned that the implementation of RHNA numbers as allocated contradicts other laws (SB 375 and AB 32) that require Sustainable Community Strategies (SCS). The draft SCS prepared by SACOG is consistent with the “Blueprint” previously adopted by SACOG that was the model for drafting of SB 375. The Blueprint calls for redirecting development into areas that have jobs and mass transit and other urban services to support increased population.

November 21, 2011 RHNA Response to Written Comments Page 15

Despite major commitments to such “Smart Growth,” The Sacramento Bee reported on November 5, 2011 that the region has spread out at a faster rate than in decades past. The RHNA allocations exacerbate this problem by requiring communities to plan for more housing that do not have the jobs or urban services or general plans that support that. Some new legislation will be needed to reconcile these conflicting state policy goals. SACOG should identify how best to reconcile these goals, and recommend appropriate legislation to fix this problem. SACOG should then work with the League of Cities and County Supervisors Association of California to advance such legislative goals.

Response #35: SACOG staff will continue to monitor and engage in discussions about state legislative matters relating to the state Housing Element Law. It has worked with the League of California Cities, the California State Association of Counties, CALCOG, and several others that have mutual interests in this matter.

Comment #36: Letter #18, city of Folsom: SACOG should request HCD to reanalyze the RHNA process for the next 8‐year housing element period (2022‐2030) within the next two years and report to the state legislature with a recommendation for a realistic allocation process that represents market trends in housing prices and supply and achievable land use patterns within these trends to determine RHNA target numbers.

Response #36: Comment noted. SACOG staff will continue to work with HCD to identify issues and seek to improve the state Housing Element Law.

November 21, 2011 RHNA Response to Written Comments Page 16

APPENDIX 3

Excerpts from California Government Code Section 65584 Excerpts from Housing Element Law

California Government Code Section 65584 and 65584.04

California Government Code Section 65584

(a)(1)For the fourth and subsequent revisions of the housing element pursuant to Section 65588, the department shall determine the existing and projected need for housing for each region pursuant to this article. For purposes of subdivision (a) of Section 65583, the share of a city or county of the regional housing need shall include that share of the housing need of persons at all income levels within the area significantly affected by the general plan of the city or county.

(2)While it is the intent of the Legislature that cities, counties, and cities and counties should undertake all necessary actions to encourage, promote, and facilitate the development of housing to accommodate the entire regional housing need, it is recognized, however, that future housing production may not equal the regional housing need established for planning purposes.

(b)The department, in consultation with each council of governments, shall determine each region's existing and projected housing need pursuant to Section 65584.01 at least two years prior to the scheduled revision required pursuant to Section 65588. The appropriate council of governments, or for cities and counties without a council of governments, the department, shall adopt a final regional housing need plan that allocates a share of the regional housing need to each city, county, or city and county at least one year prior to the scheduled revision for the region required by Section 65588. The allocation plan prepared by a council of governments shall be prepared pursuant to Sections 65584.04 and 65584.05 with the advice of the department.

(c)Notwithstanding any other provision of law, the due dates for the determinations of the department or for the council of governments, respectively, regarding the regional housing need may be extended by the department by not more than 60 days if the extension will enable access to more recent critical population or housing data from a pending or recent release of the United States Census Bureau or the Department of Finance. If the due date for the determination of the department or the council of governments is extended for this reason, the department shall extend the corresponding housing element revision deadline pursuant to Section 65588 by not more than 60 days.

(d)The regional housing needs allocation plan shall be consistent with all of 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, and the encouragement of efficient development patterns. (3)Promoting an improved intraregional relationship between jobs and housing.

(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 decennial United States census.

(e)For purposes of this section, "household income levels" are as determined by the department as of the most recent decennial census pursuant to the following code sections:

(1)Very low incomes as defined by Section 50105 of the Health and Safety Code.

(2)Lower incomes, as defined by Section 50079.5 of the Health and Safety Code.

(3)Moderate incomes, as defined by Section 50093 of the Health and Safety Code.

(4)Above moderate incomes are those exceeding the moderate-income level of Section 50093 of the Health and Safety Code.

(f)Notwithstanding any other provision of law, determinations made by the department, a council of governments, or a city or county pursuant to this section or Section 65584.01, 65584.02, 65584.03, 65584.04, 65584.05, 65584.06, 65584.07, or 65584.08 are exempt from the California Environmental Quality Act (Division 13 (commencing with Section 21000) of the Public Resources Code).

California Government Code Section 65584.04

(a)At least two years prior to a scheduled revision required by Section 65588, each council of governments, or delegate subregion as applicable, shall develop a proposed methodology for distributing the existing and projected regional housing need to cities, counties, and cities and counties within the region or within the subregion, where applicable pursuant to this section. The methodology shall be consistent with the objectives listed in subdivision (d) of Section 65584.

(b)(1)No more than six months prior to the development of a proposed methodology for distributing the existing and projected housing need, each council of governments shall survey each of its member jurisdictions to request, at a minimum, information regarding the factors listed in subdivision (d) that will allow the development of a methodology based upon the factors established in subdivision (d).

(2)The council of governments shall seek to obtain the information in a manner and format that is comparable throughout the region and utilize readily available data to the extent possible.

(3)The information provided by a local government pursuant to this section shall be used, to the extent possible, by the council of governments, or delegate subregion as applicable, as source information for the methodology developed pursuant to this section. The survey shall state that none of the information received may be used as a basis for reducing the total housing need established for the region pursuant to Section 65584.01.

(4)If the council of governments fails to conduct a survey pursuant to this subdivision, a city, county, or city and county may submit information related to the items listed in subdivision (d) prior to the public comment period provided for in subdivision (c).

(c)Public participation and access shall be required in the development of the methodology and in the process of drafting and adoption of the allocation of the regional housing needs. Participation by organizations other than local jurisdictions and councils of governments shall be solicited in a diligent effort to achieve public participation of all economic segments of the community. The proposed methodology, along with any relevant underlying data and assumptions, and an explanation of how information about local government conditions gathered pursuant to subdivision (b) has been used to develop the proposed methodology, and how each of the factors listed in subdivision (d) is incorporated into the methodology, shall be distributed to all cities, counties, any subregions, and members of the public who have made a written request for the proposed methodology. The council of governments, or delegate subregion, as applicable, shall conduct at least one public hearing to receive oral and written comments on the proposed methodology.

(d)To the extent that sufficient data is available from local governments pursuant to subdivision (b) or other sources, each council of governments, or delegate subregion as applicable, shall include the following factors to develop the methodology that allocates regional housing needs:

(1)Each member jurisdiction's existing and projected jobs and housing relationship.

(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.

(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 (FEMA) 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. (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.

(D)County policies to preserve prime agricultural land, as defined pursuant to Section 56064, within an unincorporated area.

(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.

(4)The market demand for housing.

(5)Agreements between a county and cities in a county to direct growth toward incorporated areas of the county.

(6)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.

(7)High-housing cost burdens.

(8)The housing needs of farmworkers.

(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.

(10)Any other factors adopted by the council of governments.

(e)The council of governments, or delegate subregion, as applicable, shall explain in writing how each of the factors described in subdivision (d) was incorporated into the methodology and how the methodology is consistent with subdivision (d) of Section 65584. The methodology may include numerical weighting.

(f)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 shall not be a justification for a determination or a reduction in the share of a city or county of the regional housing need.

(g)In addition to the factors identified pursuant to subdivision (d), the council of governments, or delegate subregion, as applicable, shall identify any existing local, regional, or state incentives, such as a priority for funding or other incentives available to those local governments that are willing to accept a higher share than proposed in the draft allocation to those local governments by the council of governments or delegate subregion pursuant to Section 65584.05. (h)Following the conclusion of the 60-day public comment period described in subdivision (c) on the proposed allocation methodology, and after making any revisions deemed appropriate by the council of governments, or delegate subregion, as applicable, as a result of comments received during the public comment period, each council of governments, or delegate subregion, as applicable, shall adopt a final regional, or subregional, housing need allocation methodology and provide notice of the adoption of the methodology to the jurisdictions within the region, or delegate subregion as applicable, and to the department.

(i)(1)It is the intent of the Legislature that housing planning be coordinated and integrated with the regional transportation plan. To achieve this goal, the allocation plan shall allocate housing units within the region consistent with the development pattern included in the sustainable communities strategy.

(2)The final allocation plan shall ensure that the total regional housing need, by income category, as determined under Section 65584, is maintained, and that each jurisdiction in the region receive an allocation of units for low- and very low income households.

(3)The resolution approving the final housing need allocation plan shall demonstrate that the plan is consistent with the sustainable communities strategy in the regional transportation plan.

Item #12-8-3 Land Use & Air Quality Committee Information

July 26, 2012

Update on MTP/SCS Implementation

Issue: Staff will provide a status report on various implementation activities for the Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS).

Recommendation: This item is for information and discussion.

Discussion: Since the Board’s adoption of the MTP/SCS for 2035 in April of this year, staff has taken steps to aid the implementation of the SCS portion of the plan. These activities are focused on the creation of tools to assist member agencies in using the California Environmental Quality Act (CEQA) streamlining benefits that are available now that the SCS is adopted and has been accepted by the California Air Resources Board. Development of these tools is funded through a combination of the first- round Strategic Growth Council grant and HUD Sustainable Communities grant.

The first tool is a worksheet for local governments to use in determining a project’s consistency with the SCS. Pursuant to Public Resources Code §§ 21155(a) and 21159.28(a), a project seeking to use SCS CEQA streamlining, whether a transit priority project or residential/mixed-use project, must be found consistent with the general land use designation, density, building intensity, and applicable policies specified for the project area in the adopted SCS. SACOG has solicited input from local agency staff on the need for, and utility of, a worksheet that might assist them in making a consistency determination and has received affirmative feedback that such a worksheet would be helpful.

The second tool under development is a model Sustainable Communities Environmental Assessment (SCEA). This is a new document created by SB375 to streamline environmental review. As part of SACOG’s Sustainable Communities grant, SACOG staff and its EIR consultant team are creating SCEAs for case study projects in Transit Priority Areas. The objectives of this work are to: demonstrate how SB375 CEQA streamlining provisions can be used to implement the MTP/SCS, demonstrate how an SCEA can be used to review a transit priority project, and create an SCEA template to encourage future use of this streamlining option.

Staff will be reaching out to local agency staff and the development community to inform them of the availability of these tools, solicit questions, and gather feedback on their effectiveness. In the coming months, staff will also compare CEQA streamlining efforts with the other MPOs that have adopted SCSs (SANDAG and SCAG) to learn what other strategies are being used to activate CEQA streamlining and tiering.

Approved by:

Mike McKeever Chief Executive Officer

MM:KL:sb Key Staff: Kirk Trost, Chief Operating Officer/General Counsel, (916) 340-6210 Rebecca Sloan, Director of External Affairs & Member Services, (916) 340-6224 Kacey Lizon, Senior Planner, (916) 340-6265 s:\sacog\board\land use & air quality committee\2012\8-august\3-mtp scs implementation.docx 13-006-01

Item #12-8-4 Land Use & Air Quality Committee Information

July 26, 2012 Water Issues Update Issue: Update on water issues. Recommendation: None; this item is informational. Discussion: Since the Committee last met, staff has continued to work with SACOG’s partners in the North State Water Alliance (Regional Water Authority, Northern California Water Association, Mountain Counties Water Resources Association, and Metro Chamber). Staff has also monitored developments with the Delta Stewardship Council’s Delta Plan and the State Natural Resources Agency and U.S. Department of Interior’s Bay Delta Conservation Plan. The Delta Stewardship Council had a statutory deadline for adopting a Delta Plan this past January. The Council is on its sixth version of the plan. The current version is significantly better than the earlier drafts, which could have had significant adverse impacts on our region. However, two issues of concern remain. In June, the North State Water Alliance wrote to the Delta Stewardship Council to express concerns about the issues of reduced reliance on the Delta and increased regional self-reliance. The letter is included as Attachment A. The Delta Stewardship Council has yet to adopt a final Delta Plan, as the issues raised by the Alliance were raised by others and have yet to be addressed. As part of the 2012-13 budget package the Legislature postponed the statewide water bond measure from November 2012 to November 2014. The Bay-Delta Conservation Plan continues to move forward as an attempt to address environmental issues related to conveyance of water through the Delta. On July 25, the Governor and U.S. Secretary of the Interior, Ken Salazar, made a statement about peripheral tunnels (Attachment B). This issue directly impacts the southern portion of the SACOG region. On July 24, the Sacramento County Board of Supervisors voted unanimously to oppose this proposal. Staff will bring forward any additional information at the committee meeting. Alliance partners Northern California Water Association and Regional Water Authority issued a response to the State- Federal statement (Attachment C). Staff was recently involved in a regional water resources tour for the State Water Resource Control Board organized by the Northern California Water Association. Staff presented the Rural-Urban Connections Strategy (RUCS) project, which was well received by the attending board members and their staff. Board members were particularly interested in the regional approach to both urban and rural planning and economic development and the technical capacity that has been built for the RUCS project. The usefulness of these tools for statewide planning and water resource analysis was noted. Approved by:

Mike McKeever Chief Executive Officer

Attachments Key Staff: Kirk Trost, Chief Operating Officer/General Counsel, (916) 340-6210 David Shabazian, Senior Planner, (916) 340-6231 Erik Johnson, Government & Media Affairs Coordinator, (916) 340-6247 Attachment A

June 12, 2012

Joe Grindstaff Executive Director Delta Stewardship Council 980 Ninth Street, Suite 1500 Sacramento, CA 95814

Dear Mr. Grindstaff:

The North State Water Alliance appreciates the progress in the Sixth Draft Delta Plan (Draft Delta Plan, May 14, 2012). As the Delta Stewardship Council (Council) takes up the matter of crafting the final Delta Plan, we remain very concerned regarding the way the Draft Delta Plan confuses the issues of “reduced reliance on the Delta” and “increased regional self-reliance” with respect to water supplies in Northern California within the Delta watershed.

As you know, the North State Water Alliance was created to promote responsible solutions for the Sacramento-San Joaquin Delta that protect the economy, environment and quality of life in Northern California. North state water suppliers and users are aggressively pursuing water use efficiency, water recycling, advanced water technologies, local and regional water supply projects, and improved regional coordination of local and regional water supply efforts, as required in Water Code §85021. We have also pursued a number of actions in the region to balance and thus ensure reliable water supplies for both economic purposes and sustainable ecosystems.

In the “Water Resources” chapter of the Draft Delta Plan, however, we believe staff has misinterpreted the language and intent of Water Code §85021 in a manner that may violate §85031(a), and would be detrimental to water suppliers serving water for various beneficial uses within the Delta watershed. The Draft Delta Plan suggests that water suppliers within the Delta watershed should decrease their future use of local water sources. This simply does not make sense for areas upstream of the Delta and it is at odds with the area-of-origin laws, the specific purpose of which is to protect the ability of communities in the Delta watershed to use their local water supplies and have maximum flexibility to meet future needs. Attachment A

Importantly, while our per capita urban use will continue to decline and farms are applying less water to their fields, the economic outputs and productivity in the region have increased. To sustain these efficiency improvements and to provide water for economic and environmental purposes throughout the region, Northern California water suppliers will continue to rely on access to existing water rights and supplies, while maximizing flexibility to actively manage the water resources in the region. These supplies are critical to meeting both present and future water supplies in a growing region with numerous demands on the water.

We therefore urge the Council to amend its concept of “regional self reliance” with respect to water users within the Delta watershed as suggested in the attached document. To protect water rights consistent with §85031(a), the Delta Plan’s interpretation of §85021 should recognize the need for maximum flexibility and the increased water use of local and regional water sources within the Delta watershed.

Thank you for the opportunity to comment on the Draft Delta Plan. We look forward to continuing to work with the Council in crafting the Final Delta Plan. If you have any questions, please contact any of the undersigned.

Very truly yours,

John Woodling David Guy Executive Director President Regional Water Authority Northern California Water Association

Roger Niello John Kingsbury President and CEO Executive Director Sacramento Metro Chamber Mountain County Water Resources Association

Mike McKeever Chief Executive Officer Sacramento Area Council of Governments

cc: Council Members

Attachment A

North State Water Alliance

Proposed Edits to Sixth Draft Delta Plan Edits to Reflect Water Code Section 85021’s Two Sentences

June 6, 2012

Issue: The sixth draft Delta Plan misinterprets Water Code section 850211 by combining the separate standards stated in section 85021’s two sentences into one metric that is unworkable for the Delta watershed. Specifically, the sixth draft states a metric under which “a significant reduction in net water use, or in the percentage of water used, from the Delta watershed” would be how consistency with section 85021 would be measured. (Sixth draft, pp. 100, 109.) This metric does not accurately reflect the second sentence in section 85021, which states:

Each region that depends on water from the Delta watershed shall improve its regional self-reliance for water through investment in water use efficiency, water recycling, advanced water technologies, local and regional water supply projects, and improved regional coordination of local and regional water supply efforts.

Several of the types of water management projects identified in this portion of section 85021 – especially, “local and regional water supply projects” and “improved regional coordination of local and regional water supply efforts” – involve existing and future water use in the Delta watershed. Such changes may be necessary not only to meet growing demands with the only available supplies, but also to allow for increased diversions in wet periods to enable reduced diversions in dry periods. For example, conjunctive-use programs in the watershed might involve such measures. Section 85021 therefore must be interpreted to allow flexibility to meet changing demands in the watershed. Section 85021 also be interpreted in this manner to be consistent with other parts of the Delta Reform Act, specifically sections 85031(a) – which protects area-of- origin rights in the watershed – and 85302(i) – which states that nothing in the Act affects “[a]ny water right.”

Solution: Revise Delta Plan discussion of section 85021 to state an appropriate metric for the Delta watershed. It must recognize that watershed agencies are necessarily dependent on local supplies to meet present and future needs. This metric should measure whether watershed agencies are implementing the management measures that the Legislature listed in section 85021’s second sentence.

1Further references to statutes are to Water Code sections.

-1-

Attachment A

Proposed Edits to Sixth Draft Delta Plan (insertion underlined, deletions in strikeout):

1. Chapter 1, page 5, lines 35-37:

Consistent with the longstanding water rights in California, it also reduces reliance on the Delta and improves regional self-reliance in areas that rely on water from the Delta watershed by recommending that all local agencies implement local or regional plans to diversify and integrate supplies and improve efficiency.

2. Chapter 1, page 21, lines 30-32:

3. Chapter 3, page 68, green text block:

Regions that use water from the Delta watershed will reduce their reliance on this water for reasonable and beneficial uses, and improve their regional self-reliance for water through investment in water use efficiency, water recycling, advanced water technologies, local and regional water supply projects, and improved regional coordination of local and regional water supply efforts, consistent with existing water rights and the State’s area of origin statutes and Reasonable Use and Public Trust Doctrines.

■ This will be done by improving, investing in, and implementing programs and projects that, among other things, increase water conservation and efficiency, increase water recycling, expand existing storage, implement new storage projects, improve groundwater management, improve source water supply reliability through integrated land use and resources management actions and enhance regional coordination of local and regional water supply development efforts, and the use of advanced water technologies.

4. Chapter 3, page 68, line 17, through page 69, line 2:

The Delta crisis cannot be resolved by taking actions in the Delta alone. The Delta Reform Act establishes a new policy for California of reducing “reliance on the Delta in meeting California’s future water supplies” (Water Code section 85021). Reduced reliance is to be achieved through “a statewide strategy of investing in improved regional supplies, conservation, and water use efficiency.” Consistent with longstanding water rights protected by the Act (Water Code section 85302(i)), the Act also states that “each region that depends on water from the Delta watershed shall improve its regional self-reliance through investment in water use efficiency, water recycling, advanced water technologies, local and regional water supply projects, and improved regional coordination of local and regional water supply efforts.”

-2-

Attachment A

5. Chapter 3, page 69, lines 7-9:

An integrated approach that includes increased water use efficiency, regional diversification and integration of water supplies, reduced reliance on water from the Delta watershed and, concurrent improvements to storage statewide and improved Delta infrastructure will help to meet California’s future water supply needs by building the resiliency and reliability of California’s water supply.

6. Chapter 3, page 69, lines 17-18:

Regions that use water from the Delta watershed will have reduced their reliance on this water improved their regional self-reliance.”

7. Chapter 3, page 76, line 36:

... appropriative) exceeds the surface water supplies that are available in some streams, if all the right-holders fully perfected and...

8. Chapter 3, page 78, lines 7-9:

As stated in Water Code section 85021, Sstate law policy is “to reduce reliance on the Delta in meeting California’s future water supply needs through a statewide strategy of investing in improved regional supplies, conservation, and water use efficiency.” now requires all water suppliers who use water from the Delta or the Delta watershed to reduce their reliance on those supplies to meet future water supply needs through a statewide strategy of investing in improved regional supplies, conservation, and water use efficiency. The State law requires that State policy also is, as also stated in Water Code section 85021, that, “(E)ach region that depends on water from the Delta watershed shall improve its regional self-reliance for water through investment in water use efficiency, water recycling, advanced water technologies, local and regional water supply projects, and improved regional coordination of local and regional water supply efforts.” (Water Code section 85021). These strategies will provide new water supplies for the coming century; will help protect the Delta’s beleaguered ecosystem; and, combined with State improvements in the Delta, will provide a more reliable water supply for California.

9. Chapter 3, page 88, lines 29-31:

. . . because of limited funding and restrictions in some of the grant provisions. The section, Local Water Management in California, later in this chapter, provides further detail on the range of options and describes necessary steps that regions should take to improve regional self-reliance and, for those regions that divert water from the Delta, contribute to the statewide goal of reducinge reliance on the Delta.”

10. Chapter, 3, page 92, lines 31-34:

-3-

Attachment A

Water developed through these activities can help reduce conflicts among urban, agricultural, and environmental uses, and can contribute to the ability of regions in California statewide to reduce their reliance on the Delta, and for those regions that depend on water from the Delta watershed, to improve their regional self- sufficiency.

11. Chapter 3, page 94, green text block, paragraph 1:

Significant improvements in water management are being implemented throughout California, especially in regions that rely upon water from the Delta. The 2010 Urban Water Management Plan updates and voluntary Integrated Regional Water Management Plan (IRWMP) grant applications filed in 2010 provide insight into what individual water agencies and regional planning efforts are doing to improve water efficiency measures and develop additional local water supplies to reduce statewide reliance on water from the Delta and, for those regions that use water from the Delta watershed, to improve their regional self-sufficiency. Some examples follow.

12. Chapter 3, page 100, lines 1-13:

An assessment of future water supply reliability is now required in Urban Water Management and Agricultural Water Management Plans as well as in voluntary regional water planning documents known as IRWMPs. For areas that rely upon water from the Delta watershed, the failure of many water suppliers to identify and evaluate actions to reduce their reliance on the Delta is a significant impediment to achieving the coequal goals.

Problem Statement

The lack of full participation by water suppliers throughout California to implement laws, programs, and projects that improve water efficiency and expand local and regional water supplies, and reduce reliance on the Delta watershed contributes to higher water demands and less water supply to meet these demands. A lack of growth in local or regional efficiency or supplies may impose greater pressure on the Delta ecosystem for its water, and more vulnerability to the impacts of climate change and catastrophic events. At a minimum, all water suppliers should demonstrate full compliance with applicable State water efficiency and management laws, goals, and regulations to demonstrate reasonable and beneficial use of the state’s water resources.

13. Chapter 3, page 100, lines 23-30:

For the purposes of this policy, “reducing reliance on the Delta and adequately contributing to improved regional self-reliance” means a significant reduction in net water use, or in the percentage of water used, from the Delta watershed, which may be achieved through investment in water use efficiency, water recycling, advanced water technologies, local and regional water supply projects, and

-4-

Attachment A

improved regional coordination of local and regional water supply efforts, and at a minimum, must be achieved through compliance with existing state laws regarding water conservation, water efficiency and urban and agricultural water management planning.

14. Chapter 3, page 101, lines 24-36:

Water suppliers that receive water from the Delta or the Delta watershed should include an expanded Water Supply Reliability Element, starting in 20120, as part of the update of its Urban Water Management Plan, Agricultural Water Management Plan, Integrated Water Management Plan or other plan that provides equivalent information about the supplier’s planned investments in water use efficiency conservation and water supply development. The expanded Water Supply Reliability Element should detail how those water suppliers who receive water from the Delta are contributing to the goal of reducing reliance on the Delta. Those water users who receive water from the Delta watershed should show how they are improving regional self-reliance. The plans should illustrate the programs and projects that will be consistent with and improving regional self-reliance consistent with Water Code section 85021. through investments in local and regional programs and projects, and should document achievement of a reduction in net water use, or in percentage of water used from the Delta watershed. At a minimum, these plans should include a plan for possible interruption of Delta any water supplies exported from the Delta up to 36 months due to catastrophic events, evaluation of the regional water balance, a climate change vulnerability assessment and an evaluation of the extent to which the supplier’s rate structure promotes and sustains efficient water use.”

15. Chapter 3, page 101, line 41:

. . . suppliers can implement WR - R4 by 201520.

16. Chapter 3, page 103, lines 12-16:2

Water suppliers that receive water from the Delta watershed, and that obtain a significant percentage of their long-term average water supplies from groundwater sources should develop and implement sustainable groundwater management plans that are consistent with both the required and recommended components of local groundwater management plans identified by the Department of Water Resources’ Bulletin 118 (Update 2003) by December 31, 2014. “

17. Chapter 3, page 108, lines 13-18:

Reduced Reliance for water use from on the Delta Watershed and improved regional self-reliance for those agencies that receive water from the Delta

2The groundwater storage graph on page 97 of the sixth draft Delta Plan indicates that there is no significant overall groundwater problem in the Delta watershed, which comprises the Sacramento, Delta and Eastside Streams and San Joaquin Basin.

-5-

Attachment A

watershed. The Delta Plan identifies two core measures of water management consistent with Water Code section 85021. The first is for statewide reduced reliance on the Delta for meeting future water supply needs. The second is that each region that depends on water from the Delta watershed shall improve its regional self-reliance.: a significant reduction in net water use, or in the percentage of water used, from the Delta watershed. Potential additional measures should be identified and evaluated, especially those that, when implemented in the Delta and the upper watershed, will benefit the Delta (amount of water, quality of water, and timing of flows) and contribute to reduced reliance on the Delta watershed, consistent with Water Code section 85021.

18. Chapter 3, page 109, lines 6-8:

Water suppliers that receive water from the Delta watershed have documented achievements of improved regional self-reliance through investment in water use efficiency, water recycling, advanced water technologies, local and regional water supply projects, and improved regional coordination of local and regional water supply efforts, consistent with existing water rights and the State’s area of origin statutes and Reasonable Use and Public Trust Doctrines.” net reductions in volume of water used from Delta or expansion of local supplies relative to Delta water use. (WR R4)

19. Chapter 6, page 229, lines 9-13:

The State Water Resources Control Board and Central Valley Regional Water Quality Control Board should consider requiring participation by all relevant water users that are supplied water from the Delta or the Delta Watershed, or discharge significant amounts of wastewater to the Delta or the Delta Watershed, and make a demonstrable contribution to the problems addressed by to participate in the Central Valley Salinity Alternatives for Long-Term Sustainability Program (CV- SALTS) to participate in that program.

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Attachment B

Date: July 25, 2012 Richard Stapler (California): (916) 653-9402 Blake Androff (DOI): 202-208-6416 Jim Milbury (NOAA): 310-245-7114

Governor Brown and Obama Administration Outline Path Forward for Bay Delta Conservation Plan California, Interior, NOAA Reaffirm commitment to comprehensive solution to California’s water supplies and a healthy ecosystem

SACRAMENTO, CA – California Governor Edmund G. Brown Jr., Secretary of the Interior Ken Salazar, and National Oceanic and Atmospheric Administration (NOAA) Assistant Administrator for Fisheries Eric Schwaab today outlined revisions to the proposed Bay Delta Conservation Plan (BDCP) that, along with a full range of alternative proposals, will undergo a rigorous public environmental review in the coming months. In announcing the path forward for an enhanced BDCP process, the officials emphasized that California’s water system is unsustainable from an environmental and economic perspective, and that the BDCP is a key part of a comprehensive solution to achieve the dual goals of a reliable water supply for California and a healthy California Bay Delta ecosystem that supports the State’s economy.

Population growth, habitat loss and ongoing threats to levee stability and water supply have crippled the California Bay Delta, threatening the health and economies of California communities. The revised approach, which is grounded in science, is designed to help restore fish populations, protect water quality, and improve the reliability of water supplies for all water users who receive deliveries from state and federal projects. It improves on key aspects of previous proposals and offers a strong governance model, financing options, a scientific review process and a steadfast conservation foundation for a new water conveyance facility to move water and help restore the health of the ecosystem.

"A healthy Delta ecosystem and a reliable water supply are profoundly important to California's future," said Governor Brown. "This proposal balances the concerns of those who live and work in the Delta, those who rely on it for water and those who appreciate its beauty, fish, waterfowl and wildlife."

“As broken and outdated as California’s water system is, we are also closer than ever to forging a lasting and sustainable solution that strengthens California’s water security and restores the health of the Delta,” said Secretary Salazar. “Through our joint federal-state partnership, and with science as our guide, we are a taking a comprehensive approach to tackling California’s water problems when it comes to increasing efficiency and improving conservation. Today marks an important step forward in transforming a shared vision into a practical, effective solution. With California’s water system at constant risk of failure, nobody can afford the dangers or costs of inaction.”

“The status quo isn’t working for fish, communities around or dependent upon the Bay Delta, economic development, or water resources management,” said Dr. Jane Lubchenco, Under Secretary of Commerce for Oceans and Atmosphere and NOAA Administrator. “Our proposed changes to the BDCP reflect important improvements in shaping a comprehensive strategy to fix a broken system. Because this is a complicated issue and we do not have all the answers today, we will continue to evaluate and refine the proposal. We call upon the many participants throughout California to join us in staying focused on science-based solutions.”

The elements of a preferred proposal include the construction of water intake facilities with a total capacity of 9,000 cubic feet per second -- down from an earlier proposal of 15,000 cfs – operations of which would be phased in over several years and a conveyance designed to use gravity flow to maximize energy efficiency and to minimize environmental impact. Many other alternatives, including no conveyance facility, and facilities with capacities ranging from 3,000 to 15,000 cfs, will also be fully considered as part of the upcoming environmental review process.

Governor Brown and Secretary Salazar affirmed their commitment to continue working with water users, non- governmental organizations and local governments to achieve the co-equal goals in a manner that incentivizes reduced, efficient water use throughout California and that protects and enhances the unique cultural, recreational, natural resource, and agricultural values of the Delta.

Having identified the key elements of a proposal, the parties expect to issue a draft Bay Delta Conservation Plan and corresponding Environmental Impact Report/Environmental Impact Statement for public review this fall. In recognition that water supply reliability and affordability elements are vitally important to the public water agencies who are expected to pay for any proposed facilities, the state and federal agencies will work intensively with the public water agencies and other interested parties over the next 90 days to address these important questions. State and federal agencies will continue to refine the proposals announced today and will issue a major progress report after the completion of this initial work.

The proposal outlined today is based on shared objectives, including:  Science: In order to determine the benefits of additional habitat and Delta outflow to fish, the State and U.S. governments are developing a process, including independent scientific review, to ensure that science is playing a neutral and informative role in determining a way forward for the BDCP. All parties, including water users, conservation groups and public agencies will be invited to fully participate in the process. Science will guide how to best restore the ecosystem and how much water can be exported.

 Conservation: The BDCP will contain biological goals and objectives to improve the status of a wide variety of listed species and species of concern under the Endangered Species Act, and will quickly implement new habitat projects in the Suisun Marsh and the Delta upon completion of appropriate environmental reviews.

 Cooperation and Governance: State and U.S. governments will work cooperatively with local water agencies, environmental organizations, and Delta governments and districts under a proposed governance structure to achieve an open, transparent, and inclusive process, allowing affected parties to play an appropriate role in the governance and implementation of the BDCP.

 Finance: State and U.S. governments are committed to the “user pay” principle, and the state and federal water contractors agree that the costs of the new water conveyance facility and associated mitigation of that facility will be paid through charges to the water users who would benefit from its development and operation. Habitat and other conservation measures in the BDCP would be financed in part by the contractors, but would mostly be paid by the state over a period of 40 years, with likely additional investment by the federal government through existing programs.

 Adaptive Management: The proposal reflects the shared commitment by state and U.S. governments to incorporate adaptive management to ensure flexibility as factors such as climate change, new invasive species, and unexpected prolonged drought continue to affect the biology and water supplies of the Delta. s  Sustaining Delta Communities: The State and U.S. governments recognize the need to preserve the unique communities and agricultural productivity of the Delta. State and federal agencies will continue investment in the Delta for flood protection, community development, and biological restoration.

 Protecting Upstream Water Users: State and U.S. governments will make sure implementation of BDCP will not result in adverse effects on the water rights of those in the watershed of the Delta, nor will it impose any obligations on water users upstream of the Delta to supplement flows in and through the Delta.

 Improved Water Management State-wide: State and U.S. governments will continue to explore new ways to satisfy competing water demands, including commitments to an Integrated Water Management approach, reducing water demand, increasing water supply, and improving efficiency of operations. The Metropolitan Water District of Southern California and the Santa Clara Valley Water District - the two largest urban regional water agencies-- have committed to exceed the urban water savings target established in the 2009 Delta Reform Act by saving 700,000 acre-feet a year based on predicted future demands. This includes a commitment by Southern California to annually save more water through conservation and recycling than it receives, on average, from Northern California, as well as a commitment from the Santa Clara County Water District to meet Silicon Valley’s future increases in demand through conservation and recycling. With respect to agricultural water use, the Bureau of Reclamation has worked with local water agencies to invest close to $50 million over the last eight years in efficiency improvements in California. Reclamation is now partnering with the Natural Resources Conservation Service to provide funding for projects that improve water management and create new supplies for agricultural irrigation. In the last two years, approximately $15 million in federal funding has been invested in this effort. The State of California has invested more than $47 million in similar programs since 2001.

For more information on today’s announcement, including a q&a document and information on how the proposal is expected to improve fish species, please visit: http://baydeltaconservationplan.com

### Attachment C

Statement on the Bay-Delta July 25, 2012

We appreciate Governor Brown, Secretary of Interior Salazar and NOAA Assistant Administor Schwaab gathering today to acknowledge that California has many important challenges in advancing a sound water policy that stabilizes water supplies for the future of California’s economy and environment.

It is no secret that California has too many disparate efforts underway that will further destabilize California’s water system and stifle progress toward an environmentally and economically sustainable Bay-Delta solution. The new level of assertive leadership shown today and the active coordination of these various state and federal processes is critical to ensure that the state’s co-equal goals are not only met, but that sound decisions are made in a judicious manner to begin providing stability to California’s water system. We are both hopeful and encouraged that today marks the beginning of more concerted and coordinated leadership towards a Bay-Delta solution.

Since the inception of the Bay-Delta Conservation Plan (BDCP) process, water suppliers that divert water upstream of the Delta have been actively following the BDCP process. Importantly, these entities will not be covered by the approvals and permits issued for the BDCP and will not rely upon the BDCP or related processes focused on the Delta to receive their water supplies. Thus, we have not directly participated in the BDCP process; however, upstream water suppliers have supported the state’s co-equal goals and have encouraged success in the formulation of the BDCP and related actions to help resolve the challenges in the Delta with an eye to stability in California’s water system. Our ability to help the BDCP process and related Delta-processes succeed is predicated upon the fact that water rights, supplies and regional self-sufficiency in areas upstream of the Delta will be fully honored. We laud the leadership and commitment today to “make sure implementation of BDCP will not result in adverse effects on the water rights of those in the watershed of the Delta, nor will it impose any obligations on water users upstream of the Delta to supplement flows in and through the Delta.” For the various Bay-Delta processes to be successful, the direct beneficiaries of these actions in the Bay-Delta must step forward and be fully responsible for any impacts or obligations (including appropriate mitigation) related to any flows and funding in these processes, and they must not injure any legal user of water or fish and wildlife upstream of the Delta. For the area upstream of the Delta we represent, we remain committed to continue collaborative efforts to further develop innovative solutions that will benefit both the economy and the environment. We have a strong track record in this arena. The Sacramento Valley joins together a world-renowned mosaic of natural abundance: productive farmlands, wildlife refuges and managed wetlands, cities and rural communities, and meandering rivers that support and feed fisheries and natural habitats. Through efficient management of the region’s water resources, the Sacramento Valley will continue to provide what’s essential to California’s future success and prosperity: nourishment and sustenance from the fields, habitats for fish and wildlife, recreation and a special quality of life—the Sacramento Valley is home to all of this, and more. Our path forward is rooted in our continuing ability to rely upon our own water supplies to provide water for all these beneficial purposes—both now and into the future. Additionally, if the state and federal agencies are serious about achieving the co-equal goals of “providing a more reliable water supply for California and protecting, restoring and enhancing the Delta ecosystem,” then new surface storage, such as Sites Reservoir in the Sacramento Valley, must be integrated with conveyance to maximize the operational flexibility of the existing water system. This linkage between smart storage and conveyance is critical for the future of California. This, in turn, will provide more stability to California’s water system. We look forward to working with state and federal leaders as well as our various partners, in developing a solution to the Bay-Delta. If you have any questions, please call David Guy at 916-442-8333 or John Woodling at 916-967-7692. For more information, please visit the North State Water Alliance website at www.northstatewater.org. A description of “What’s at Stake? The importance of protecting water resources in the Sacramento Valley” can be viewed at http://www.norcalwater.org/wp- content/uploads/2012/07/17781_NCWA_WhatsAtStakeBrochure_v1_a10_FINAL_single _LR.pdf.

Item #12-8-5 Land Use & Air Quality Committee Information

July 26, 2012

Flood Issues Update Issue: Update on flood issues. Recommendation: None; this item is informational. Discussion: In March, staff presented the Board with an overview of federal flood policy issues and recommendations for continued agency involvement. Part of the Board action directed the CEO to increase the agency’s ongoing understanding of flood control issues so that if Board action on specific legislation is appropriate in the future, sufficient background information is available to support its deliberations.

Since that time, staff and several Board members attended the Cap-to-Cap program in Washington, DC. Staff has also met several times with the Metro Chamber’s Flood and Water Committee and individually with groups representing flood control agencies in the region. Staff is arranging a series of Board workshops in the coming months on the Central Valley Flood Protection Plan as well as current flood protection efforts around the region.

Approved by:

Mike McKeever Chief Executive Officer

MM:EJ:sb

Key Staff: Kirk Trost, Chief Operating Officer/General Counsel, (916) 340-6210 David Shabazian, Senior Planner, (916) 340-6231 Erik Johnson, Government & Media Affairs Coordinator, (916) 340-6247

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Item #12-8-6 Land Use & Air Quality Committee Information

July 26, 2012

Regional Habitat Conservation Plans Update

Issue: Regional Habitat Conservation Plans.

Recommendation: None; this item is for information only.

Discussion: Stacey McKinley, consultant to SACOG, will update the Land Use & Air Quality Committee on the South Sacramento HCP (SSHCP) and the Placer County Conservation Plan (PCCP).

Approved by:

Mike McKeever Chief Executive Officer

MM:sb

Key Staff: Rebecca Sloan, Director of External Affairs and Member Services, (916) 340-6224

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Item #12-8-7 Land Use & Air Quality Committee Information

July 26, 2012

Six-County Aquatic Resources Inventory Project Update

Issue: Update for the USACE Six-County Aquatic Resources Inventory Project.

Recommendation: None; this item is for information only.

Discussion: Stacey McKinley, consultant to SACOG, will update the committee on the U.S. Army Corps of Engineers (USACE) Six-County Aquatic Resources Inventory. McKinley will brief the committee on the implementation plan and on the ongoing policy discussions involving integration of the project findings into the region's Habitat Conservation Plans.

Approved by:

Mike McKeever Chief Executive Officer

MM:sb

Key Staff: Rebecca Sloan, Director of External Affairs and Member Services, (916) 340-6224

S:\SACOG\Board\Land Use & Air Quality Committee\2012\8-August\7-Six-County Aquatic Resources.doc 13-005-05