State Mandated Affordable Housing Units | Major Pushback on Quotas

SCAG Members Seek Big Reductions in RHNA Allocations

SOURCE: Google Maps

Nearly a quarter of the of 197 municipal and county members of the Southern California Association of Governments have appealed the number of affordable housing units the state is ordering them to plan for over the next eight years under the Sixth Cycle of the Regional Housing Needs Assessment (RHNA). The 47 appellants are seeking an average reduction of 43.5 percent.

South Pasadena requested a 41 percent reduction, or 846 units from the 2,062 it was allocated under a methodology adopt by SCAG. Six other San Gabriel Valley cities also filed appeals: Pasadena wants a 21.8 percent reduction from its 9,409 allocation; El Monte, 37 percent from 8,481; Alhambra, 51.2 percent from 6,808; Temple City, 45.2 percent from 2,182; and San Dimas, 80.3 percent from 1,245. San Gabriel did not state an exact figure.

Yorba Linda, Lawndale and Westminster are the most aggressive appellants, asking for reductions averaging 89 percent. They are topped only by Huntington Beach, which got an allocation of 13,337 units. The city argued it’s eligible for a 17,815-unit adjustment, a reduction of 133.6 percent. Its appeal included 22 attachments with over 3,300 pages. It complained its allocation was arbitrary and driven by “last minute political wrangling.”

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All told, the 45 cities and two counties sought reductions totaling 115,128 units. That doesn’t include five appellants that sought reductions but did not state an exact figure. Using 43.5 percent as a benchmark, their reductions would add another 23,691 units.

That would bring the appellants’ total ask to over 138,819 units — more than 10 percent of the 1,341,827-unit “regional housing need” SCAG allocated pursuant to a mandate from the California Department of Housing and Community Development.

The percentage matters because under the rules, if the adjustments approved total less than 7 percent of the regional need, SCAG would redistribute them proportionally among all members. Anything above 7 percent gets redistributed among SCAG’s six county members.

Even if SCAG grants an appeal, “they saddle another city with the number,” said Abel Avalos, director of community development for the City of Lakewood, which wants a 36 percent reduction off its 3,914-unit allocation. SCAG just spreads the number among the cities, “pitting us against each other.”

The fighting has already begun.

Santa Ana got an allocation of 3,087 and did not file an appeal. But four of its neighbors — Garden Grove, Irvine, Newport Beach and Yorba Linda — all while seeking their own reductions, filed petitions asking that Santa Ana’s share be raised between 229 percent to 746 percent. They argue Santa Ana submitted growth projections that omit tens of thousands of units already under development or envisioned in existing plans, and that SCAG misallocated units that should have been in Santa Ana to neighboring cities that have less access to transit and longer drives to job centers.

Under the rules, appeals can be filed only under any combination of a set of 18 general categories.

The vast majority of appellants cited SCAG’s failure to properly comply with the adopted methodology for calculating the allocations; the availability of land for residential or urban use; and factors related to the furtherance of the state’s Fair Housing Code.

More than half of the appellants also cited “changed circumstances.”

About a dozen cited one or more of the following: the existing or projected “jobs-housing balance”; sewer or water infrastructure constraints; lands statutorily protected from urban development; greenhouse gas emission targets; the need to further fair housing; and problems associated with the distribution of household growth with respect to regional transportation plans.

Many of the cities are believed to be ramping up for a legal challenge to the RHNA allocation writ large.

“For nearly quite as long as charter city home rule has been established in our [State] Constitution,” Huntington Beach noted in its appeal, “the Legislature has consistently recognized charter cities’ local control and home rule over their land use and zoning decisions. The State is now using a housing crisis and environmental greenhouse gas reduction goals to force one-size-fits-all land use policies upon charter cities. However it is the City’s contention…that the City knows best how to manage the use of its land and resources to meet local needs. The State’s attempt to impose RHNA allocation requirements is in and of itself an illegal act.”

In other jurisdictions, appeals have had minimal results. Four of the 19 local government members of the San Diego Association of Governments appealed their 6th Cycle RHNA allocations. On July 20, SANDAG rejected appeals filed by Solana Beach and Lemon Grove. Imperial Beach and Coronado got small reductions of 2.1 percent and 3.4 percent, respectively.

Meantime SCAG’s RHNA Appeals Board, made up of six elected officials, has set Dec. 21 as the date for the first appeal hearing it will hold for seven appellants, none of which are in LA County. It has set eight more dates in January to consider other groups of appellants. All six of the San Gabriel Valley appellants will be heard at one of the January hearings, though SCAG is not expected to announce which one until next week at the earliest.

SCAG has also set Dec. 7 for a virtual orientation session for the RHNA Appeals Board that the public can also attend. It will offer a brief recap of the RHNA process to date, a refresher of RHNA appeals procedures and an overview of the hearing schedule.



Ben Tansey
Ben Tansey is a journalist and author. He grew up in the South Bay and is a graduate of Evergreen State College. He worked in Washington State as a reporter in a rural timber community and for many years as an editor for a Western electric energy policy publication based in Seattle.


  1. the City of South Pas should have a direct representative on the SCAG board. That representative would be representing Glendale, La Canada, So Pas and Pasadena. That selected representative should have made a priority to be on the RHNA committee to ensure these high quotas were reduced to levels that the cities could effectively plan for. Apparently our planning departments and city council were not active enough. The RHNA in 2004 to 2012 South Pasadena’s allocation was fought and held to 119 total units.