HomeMy WebLinkAbout25- Development Services CITY OF SAN BERNARDINO - REQUEST FOR COUNCIL ACTION
From: Michael Hays, Director Subject: Resolution objecting to the
Regional Housing Needs (RHNA)process.
Dept: Development Services
Date: March 29, 2000 0R I U` I NA L MCC Mtg. of April 3, 2000
Synopsis of Previous Council Action:
None
Recommended Motion: That the Mayor and Common Council adopt the resolution
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ichael s
Contact person: Valerie C. Ross Phone: 384.5057
Supporting data attached: Staff report resolution Ward: Citywide
FUNDING REQUIREMENTS: Amount: N/A
Source:
Finance:
Council Notes:
Agenda Item No.
aYlo-5/000
CITY OF SAN BERNARDINQ—REQUEST FOR COUNCIL ACTION
STAFF REPORT
SUBJECT: Adoption of a resolution objecting to the Southern California Association
of Government's Regional Housing Needs Assessment process for
establishing housing construction targets.
Mayor and Common Council Meeting of April 3, 2000
BACKGROUND
Regional Housing Needs Assessment Preparation
The Southern California Association of Governments(SCAG) is responsible for
developing the Regional Housing Needs Assessment(RHNA) in cooperation with the
State Department of Housing and Community Development, and allocating fair share
distributions to all jurisdictions within its region. SCAG is comprised of the counties of
Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura, and all of the
cities within those counties.
SCAG developed a model based on household growth,vacancy need, housing unit losses,
and a fair share adjustment. These factors were used to determine the fair-share
distribution of housing units in the -ry Fw, low,moderate, and above moderate
categories. It is our opinion that the baz°line data Lsed=n this model is outdated and
inaccurate, and is derived from different time periods going back as far as the 1990
Census. The use of this data has resulted in underestimates in certain areas (vacancies)
and overestimates in others (housing unit loss and household growth).
Purnose of the RHNA
The RHNA is a 5-year plan for the production of housing units, and forms the basis of the
City's housing element. The City must determine if there is adequate land available at
various densities to accommodate the production of units identified in the RHNA, and
develop programs to implement those goals. The housing element must be reviewed by
HCD,prior to adoption by the City. Comments from HCD must be addressed,potentially
requiring revisions to the housing el°men*. Suce.ess-U preparation of the housing element
means that HCD will certify that th. housing ekcrmr_t meets the intent of State law.
Noncompliance with the RHNA means that jurisdictions will not receive certification
which leads to the risk of a lawsuit on the grounds that the General Plan, and specifically
the housing element are inadequate. It also means that jurisdictions could forfeit certain
State housing funds. The housing element, in turn, forms the basis of the Consolidated
Plan prepared by the Economic Development Agency.
RHNA Process
2
RHNA Appeal Process
The City submitted an appeal of the RHNA on the basis that the vacancy rate was too
low, the housing unit loss was too low, and the household growth was too high. (Refer to
Attachment 1.) SCAG established a meet and confer process for evaluationg appeals. At
the meet and confer on March 15, 2000, SCAG staff concluded that our challenge had no
merit on technical grounds. Of the 29 jurisdictions in SB County, 19 were present. The
County, Chino Hills, and Victorville also filed challenges. SCAG staff determined that
the County's request for a reduction of 14,000 units and Victorville's request for a
reduction of 1200 units were reasonable. However, SCAG's zero-sum policy requires
that reductions in housing units be reallocated to other cities within the same region.
Therefore, if the County and Victorville lose units,they must be reallocated within the
County. That means that the City could potentially gain units even though we feel that
our allocation is already too high. Victorville withdrew its appeal, and the County
indicated that it was likely to also.
Planning and EDA staff believe that the City of San Bernardino already has more than its
fair share of affordable housing and we are being allocated a disproportionate share. In
fact the Inland Empire has more than its fair share and the surrounding jurisdictions share
that belief Throughout the SCAG region,jurisdictions that already provide large
amounts of affordable housing are being assigned disproportionately high numbers once
again.
The following table illustrates income levels and the RHNA in the City of San
Bernardino. The very low and low categories total 48%of the City's allocation.
Income Levels
Income Definition 2000 Income Affordability 5-Year RHNA %
Level 1 RHNA
Very Low <50%of median $23,700 $75,000 1,148 30%
Low 50-80% of median $37,000 $120,000 676 180%
Moderate 80-120%of median $56,880 $179,000 734 190%
Above Moderate >120% of median $56,881+ $1791000+ 1,223 32%
3,782
In 1997,the median income in the City of San Bernardino was $33,381 for a family of 4.
1 1999 median income for a family of 4 in San Bernardino County.
2 Housing affordability level.
RHNA Process
3
Current Status
Planning and EDA staff will attend the Regional Housing Needs Allocation Appeals
Subcommittee [of the Community Economic Human Development Committee(CEHD)]
meeting on March 31, 2000. The subcommittee's recommendations will be forwarded to
the CEHD and then the full Regional Council. The CEHD meets on April 5`h and the
Regional Council meets April 6h. SCAG staff will recommend the Regional Council
deny our appeal and has indicated that it is not likely that the CEHD or the Regional
Council will reverse staff s recommendation.
Staff considered submitting our RHNA appeal document to the Department of Finance
(DOF)with a request that our vacancy need numbers be changed to reflect the actual
vacancy rates in the City. If successful, this could result in a reduction in the vacancy
numbers and a corresponding reduction in the RHNA. However, given the time
constraints and the amount of research and analysis required to determine the impact to
the City's subventions, staff does not recommend pursuing this option. In addition, there
may not be a long-term benefit in that the City's numbers may be readjusted based on the
2000 Census.
Conclusion
Jurisdictions are dissatisfied with their unit allocations and the RHNA appeal process,
in general. Most of the jurisdictions in San Bernardino County did not appeal their
numbers either because they did not feel that it would be worthwhile, or they did not
have the funding or resources to mount an appeal. However, there was a general
consensus that the Inland Empire was again being used as a dumping ground. The
perceived lack of support from SCAG staff and inequities of the process were noted by
all jurisdictions attending the meet and confer meeting. The dissatisfaction and
frustration with the process is not limited to the SANBAG subregion - it extends to the
majority of the 14 SCAG subregions.
There is general consensus that the original purpose of the RHNA is being
circumvented. It is staffs understanding the RHNA is intended to place affordable
housing in areas where it is actually needed, not in areas that are already impacted. The
RHNA does not take into account any local variables. For example, the City of San
Bernardino has one of the highest rates of HUD foreclosures in the United States. In
1997 alone, there were more than 1000 HUD units available. This does not include
foreclosures through financial institutions. The recession of the 1990s was felt statewide
and the City has not fully recovered. In the early 1990s, the City averaged about 500
units annually. However, from 1994-1998, less than 100 units per year were
constructed.
RHNA Process
4
The Mayor has requested that SANBAG place the SCAG RHNA process on its agenda
for April 5' for action supporting the member jurisdictions and the objections to the
RHNA process. SANBAG has offered to coordinate an effort for Inland Empire
jurisdictions to make a "significant policy statement."
FINANCIAL IMPACT
There is no financial impact to the City associated with adoption of the resolution.
RECOMMENDATION
Staff recommends that the Mayor and Common Council adopt the resolution that outlines
the City's objections with SCAG's RHNA process for establishing housing construction
targets.
Attachments: 1 City's Appeal
2 SCAG's Response to Appeal
3 Resolution
ATTACHMENT 1
C I T Y O F
. 0,o Z San Bernardino
O F F I C E O F T H E M A Y O R
J U D 1 T N V A L L E 5
M A Y O R
January 31, 2000
Mr. Joe Cameras
Southern California Association of Governments
Comprehensive Planning
818 West 7(h Street, 12"' Floor
Los Angeles, California 90017-3435
RE: Appeal of Adopted Regional Housing Needs Assessments (RHNA)
Dear Mr. Cameras:
Enclosed please find the City's Appeal Form and the supporting documentation
that explains in detail the basis of our appeal. A lot has happened in the City
since the 1990 Census and the development boom of the late 1980s. Many cities
in the Inland Empire were deeply affected by the economic recession in the early
1990s. San Bernardino was particularly hard hit in that we lost several major
employers and revenue sources such as Norton Air Force Base, and the
Atchison, Topeka, and Santa Fe Shops Oust to name a few). These losses
directly affected the City's housing stock in some very negative ways that were
not readily apparent when staff reviewed the 2005 Household Forecast numbers
in 1999.
The City was very surprised by the high construction need numbers in the
preliminary and adopted RHNA. The analysis in the attached document shows
that the City's actual vacancy rate is more than double the rate in the adopted
RHNA, and similarly, the actual housing unit loss figure is substantially lower
than in the RHNA. Given the depressed condition of the City's housing market, it
is highly unlikely that we will be able to construct 3,782 units over the next five
years.
3 0 0 N O R T H D S T R E E T . S A N R E R N A R D I N O
C A L I F O R N I A 9 2 4 1 6 - 0 0 0 1
(00 F) 3 6 4 - ! 1 3 9 • FA %-(9S 9) 661 - 6967
• RHNA Appeal
January 31, 2000
Page 2
The City is committed to providing housing opportunities for all income levels.
However, we believe that the City's allocation is unrealistic, and unattainable. For
these reasons, we submit our appeal.
Please contact Deborah Woldruff, Development Services Department at
909.384.5057 if you have any questions regarding the City's Appeal of the
RHNA.
Since y,
C L'rc z�
/J ud' h Valles,
Mayor
Enclosure: RHNA Appeal Form and Supporting Documentation
cc: Zev Yaroslaysky, SCAG President
SCAG
818 West 7`h Street
Los Angeles, CA 90017-3435
Fred Wilson, City Administrator
Michael E. Hays, Director of Development Services
Maggie Pacheco, Director of Community Development & Housing
I
APPEAL INFORMATION FORM
NAME OF JURISDICTION City of San Bernardino
DATE January 27, 2000
CONTACT PERSON
NAME Deborah Woldruff PHONE (909) 384-5057
De0v eNo pmD t SSvrcst ADDRESS 0 ee
FAX (909) 384-5080
San Bernardino CA
92418 E-MAIL Woldruff_de @ci.san-bernardino.
ca.us
APPEAL AUTHORIZED By: PLEASE CIRCLE
' f Chief Chairof
GLlerj Administrative County
Officer City Board of
Name: /. J 11'H VALLES (County) Manager Supervisors Other
BASIS FOR APPEAL
/ MAYOR
Construction Need Adopted RHNA Change Requested
HHD Growth
98 Households 59,208 59,208
05 Households 63,390 61,000
Growth 4,182 1 ,792
City's anticipated HHD Growth is less than
Explain basis for change(Brief) RHNA based on regression analysis.
Vacancy Need -755 -6,851 (Requested RHNA)
Explain basis for change(Brief) The Citc' s actual vacancy rate is 17% while
the 1990 DOF rate is at 7.6%.
Replacement Need 355 193 (Requested RHNA)
Explain basis for change (Brief) The City's actual unit loss was less than
the adopted RHNA, based on building records
Other
Explain basis for change (Brief) Please refer to the attached Assessment
Existing Need Document for basis of appeal.
1998 Households w/Housing Problems N/A
1998 Lower Income Households w/
Housing Problems N/A
1998 Lower Income Households w/
Overpayment N/A
1998 Lower Income Households wf
Overcrowding N/A
Explanation(Brief) N/A
Other
Explanation (Brief) N/A
AN ASSESSMENT OF SCAG'S
REGIONAL HOUSING NEEDS DETERMINATION
FOR THE CITY OF SAN BERNARDINO
January 25, 2000
Cotton/Beland/Associates
747 East Green Street, Suite 300
Pasadena, California 91101
(626) 304-0102
1136.00
Table of Contents
ExecutiveSummary.......................................................................1
Chart 1. San Bernardino's Recommended RHNA
I. Introduction.........................................................................3
Chart 2. SCAG's Preliminary RHNA
Chart 3. RHNA Data Sources
II. Growth Forecast ...............................................................5
Chart 4. SCAG Growth Forecast
Chart 5. City Growth Trends
Figure 1. Annexations Since 1990
Chart 6. Building Permit Trends (1990-1998)
Chart 7. Alternative 2005 Growth Forecasts
III. Vacancy Adjustment............................................................9
Chart 8. Trends in City Vacancy Rates (1990-1998)
Chart 9. Comparison of Different Vacancy Rates
Chart 10. Building Permit and Vacancy Levels
IV. Housing Unit Loss Adjustment.............................................14
Chart 11. Housing Unit Loss Data (1990-1997)
Figure 2. City Memo on Housing Losses
V. Recalculation of RHNA.........................................................16
Chart 12. City's Recommended RHNA
Figure 3. RHNA Calculation Worksheet
VI. Reallocation of Units............................................................18
VIII. Appendix............................................................................19
Exhibit A. San Bernardino Annexation Log
Exhibit B. Household Growth Worksheet
Exhibit C. American Housing Survey Data
Exhibit D. Sample Worksheet from Edison
City of San Bernardino
EXECUTIVE SUMMARY
Background
Every five years, State law requires regional governments in California to prepare a Regional
Plan for addressing housing issues related to future population and employment growth. On
November 4, 1999, the Southern California Association of Governments ("SCAG") prepared
their Regional Housing Needs Assessment ("RHNA") for jurisdictions in southern California.
The RHNA details the amount of existing and future housing needs for each community.
The City of San Bernardino's share of the region's future housing need is 3,782 housing units.
This is the amount of growth that must be planned for between January 1998 through July 2005.
The City's housing planning targets are divided into different affordability levels —very-low, low,
moderate and upper income housing. The City is responsible to satisfy its RHNA by planning
and encouraging housing production that can be afforded by households of all income levels.
State law requires every jurisdiction to prepare a 5-year housing plan, called the Housing
Element, which shows how a community will address the housing needs identified in the RHNA.
The Housing Element is submitted to the Department of Housing and Community Development
("HCD"), who reviews whether the City is allocating sufficient resources to address their housing
need. HCD then determines whether the Element is in substantial compliance with State law.
The City should strive to have HCD determine their housing element complies with State law.
If the City is sued and their Element is not approved by HCD, the City would have the legal and
costly burden of proving their Element is in substantial compliance. If HCD has already found
the Element in compliance, the burden of proof shifts to the plaintiff. Moreover, without an
approved Element, the City is at great disadvantage in competing for limited housing funds.
Because the RHNA affects local land use planning and funding,jurisdictions are authorized to
appeal their draft RHNA pursuant to State Law and SCAG's Appeal Policies and Procedures.
After reviewing their preliminary RHNA, the City of San Bernardino was concerned that their
draft RHNA did not reflect current housing market conditions. Cotton/Beland/Associates (CBA)
was thus retained to assess the accuracy of their RHNA and appeal for a reduction.
Key Findings
CBA compiled various data to analyze the housing market conditions in San Bernardino. These
included the 1990 Census, the 1994 American Housing Survey, vacancy trends based on idle
electric meters, annexation records, building permits, and various other housing market data.
Based on our review of data and analysis, the current condition of the housing market within the
City of San Bernardino precludes achieving the City's RHNA for the following reasons:
RHNA Evaluation
Page 1
City of San Bernardino
Modest Building Activity. The City of San Bernardino experienced substantial growth from
1990 to 1993, averaging approximately 500 units annually. However, with the recession in
the Inland Empire and escalating vacancy rates, the City's building permit activity plummeted
to an average of about 100 units annually. No new multifamily units were built between
1994-1998. Trends in building activity also show no signs of improvement as noted below.
High Vacancy Rates. The City's modest building activity since 1994 is simply due to a lack
of underlying market demand. In 1998, the City's current vacancy rate was 17% —twice the
vacancy rate assumed by SCAG to determine the City's RHNA planning requirements.
Moreover, industry standards confirm that vacancy rates that exceed 5-6% for rentals and
1.5-2.0% for owner-occupied homes serve to discourage residential development.
Because of the lack of market demand (e.g., continued high vacancy rates)from 1998-1999,
the City believes that residential development will not improve significantly over the
remainder of the planning period (2000-2005). Therefore, SCAG should make the following
changes to the preliminary RHNA for the City of San Bernardino:
1. Reduce the household growth forecast for 2005 to account for the slowdown
in housing market demand (due to higher vacancies) after 1993;
2. Replace the City's current subregional mobility and vacancy rate with local
data that is updated to 1994 from the American Housing Survey;
3. Replace the City's current subregional housing unit loss adjustment with
accurate local building permit data on demolitions and conversions; and
4. Not reallocate reductions in growth to other SANBAG cities, as this could
jeopardize HCD-approval of their Housing Element.
The City requests that its draft RHNA be reduced from 3,782 to zero (Chart 1). However,
should a subregional or regional reallocation of household growth become necessary to
satisfy HCD's certification of SCAG's regional housing plan, the City requests that only the
full vacancy credit be applied, leaving the household growth forecast intact.
Chart 1: City of San Bernardino
Recommended RHNA
RHNA Component Original Midpoint Preferred
Need Estimate RHNA
Household Growth 4,182 2,987 1,792
Vacancy Need -755 -3,803 -6,851
Housing Loss 355 274 193
Total Need 3,782 -542 -4,866
Source: SCAG's RHNA Calculator,CBA.
RHNA Evaluation
Page 2
City or San Bernardino
II. INTRODUCTION
Background
On November 4, 1999, the Southern California Association of Governments ("SCAG")adopted
their preliminary Regional Housing Needs Assessment ("RHNA") for the entire SCAG region.
The Regional Housing Needs Assessment identifies the amount of existing housing need within
a community (e.g., overcrowding and overpayment). The RHNA also identifies the amount of
future housing needs based upon expected growth in employment and population.
Because the RHNA impacts local land use planning and funding priorities, State law allows
jurisdictions to appeal their RHNA. Reductions can be requested due to lack of market demand,
infrastructure constraints, and various other criteria noted in State law. The only requirements
are that the appeal follow the procedural requirements set forth in State law and conform to
policies and procedures adopted by SCAG's Regional Council.
After reviewing their preliminary RHNA, the City of San Bernardino initially expressed concern
that their current RHNA allocation was not reflective of current housing market conditions.
Cotton/Beland/Associates was therefore retained by the City to assess the accuracy of their
RHNA prior to the preparation of the Housing Element. This report contains the analysis and
justification supporting the City's request for a reduction of their RHNA.
RHNA Calculation
Chart 2 outlines the four components of the Chart 2: San Bernardino
future need component of the RHNA — SCAG's Preliminary RHNA
household growth, vacancy and replacement
need, and "fair share" adjustment. Household Components fFuture percent
growth forecasts are based on a projection of employment and population over a 7.5 year Household Growth -20%period from 1998 through 2005. SCAG applies Vacancy Need 20 ,a vacancy and housing unit loss adjustment to Housing Losses 9%
ensure that a certain number of units are Total 100%
available to promote housing choice, moderate Affordability Level
costs, promote upkeep and repair, and replace very Low 1,148 30.4%
units lost to demolition, conversion or disaster. Low 676 17.9%
SCAG applies a "fair share" formula to Moderate 734 19 4%
determine the affordability mix of new housing. Upper 1 223 32,_3°i
The fair share adjustment is based on a Total" 3,782 100%
comparison of the City's income distribution $Ounce: SCAG's RHNA Website(1999)
with the County and SCAG as a whole. 'Totals may diner slightly due to rounding
RHNA Evaluation
Page 3
City of San Bernardino
Data Sources
To compile the information necessary to justify the City's appeal, CBA consulted a variety of
local, state and federal data about the City and its housing market. A brief description of each
source is noted below. It is important to note that all of the current and alternative data sources
used to recalculate the City's RHNA comply with SCAG's Appeals Policies and Procedures and
satisfy the criteria for availability, accuracy, currency, replicability, and consistency.
Chart 3: RHNA Data Sources
Data Source Purpose
1990 U.S. Census ! Data for household and housing characteristics, including
income, tenure, mobility, vacancy, etc.
1998 Department of Data for housing stock mix, household growth trends, and
Finance ("DOF") estimated vacancy rates.
1994 American Housing Data on alternative mobility information, current vacancy
Survey("AHS") rates, and other housing characteristics.
Southern California Data on electric meters (inactive and active meters) which
Edison ('SCE") ! can be used to estimate current vacancy rates.
City Building Records j Current building permit data to estimate trends in
construction, demolitions, and conversions.
Methodology
CBA developed a range of methods to estimate the City of San Bernardino's RHNA. First, CBA
analyzed trends in housing and household growth using regression analysis, both linear and
logistic trendlines,from 1990 through 1999. This was done to ensure that future projections are
based upon the regression equation that best fits historical patterns in growth. The vacancy
adjustment (both the ideal and current rates)was determined by the American Housing Survey
The accuracy of the 1994 AHS was confirmed by SCE data on inactive electric meter rates.
CBA also developed a RHNA calculator with the same formulas used by SCAG.
RHNA EvaluaGon
Page 4
City of San Bemardino
III. GROWTH FORECAST
SCAG's household growth forecast is the cornerstone of the City of San Bernardino's RHNA,
comprising the largest percentage of the RHNA. SCAG's RHNA forecast is for a 7.5 year period
from January 1, 1998 through July 1 2005. The SCAG forecast is based upon a variety of
sources, including historical trends in household growth over the past decade as well as
expected future trends in employment and population growth in and around San Bernardino.
In 1990 Census, the City had 58,969 housing units, 164,676 persons and 54,635 households.
From 1990-1998, San Bernardino experienced the following growth: an 8.9% increase in
housing units, an 8.2%, increase in households, and a 11.5% increase in total population.
Because past trends are often a good starting place for making future projections, SCAG
forecasted that the City would experience a 7% increase in households from 1998 through 2005.
The accuracy of forecasts can be shown with the statistical technique of "regression."
Regression analysis is used to analyze a series of data, in this case from 1990 through 1997,
develop a trendline that closely matches that data, and then extend the trend through Year 2005.
The accuracy of a particular forecast is measured by the regression coefficient denoted "Ra'. An
R' of 100% means that the forecast exactly matches past trends in growth.
Chart 4 below illustrates SCAG's forecast in household growth for the years 1998 through 2005.
The linear forecast explains 73% of the trend household growth from 1990-1997. In other
words, the growth forecast does not account for 27% of the variation in growth over the decade.
This is a wide margin of uncertainty unaccounted for in SCAG's forecast for the Year 2005. It
also suggests that another type of regression equation may be more appropriate.
Chart 4: City of San Bernardino
SCAG Forecast of Growth
75,000
Historical Trend
70,000
65,000 Housin0 - - -
R2=75%
60.000 - - R2=73%
55,000 - Households
50,000
1990 1992 1994 1996 1998 2000 2002 2004
RHNA Evaluation
Page 5
City of San Bernardino
Analysis of Growth Trends
SCAG's straightline growth forecast is Chart 5: City Growth Trends
problematic, because the City's growth 1990-1993 and 1994-1997
changed dramatically over the decade. 12.0%
Dividing the eight year period into two
1o.o^r,
periods shows that historical population,
housing, and household growth was 8.0%
significantly higher in the eary 1990s. iffQHouseholds
6.0%
From 1990-93, the City's population
increased approximately 6 times faster 4.0%
than during 1994-97. In addition, housing
growth was also 8 times higher and 2.0%
household growth was 13 times higher '
from 1990-1993 than from 1994-1997. 0.0%
1990-1993 1994-1997
Chart 6 explains the difference in housing and household growth over the decade. In the early
1990s, the City completed numerous annexations (as illustrated in Appendix A and Figure 1).
Meanwhile, the Inland economic boom fueled unusually high building activity. However, as the
Inland economy receded during the mid-1990s, the City stopped annexing areas. Ensuing job
losses and rising vacancy rates further depressed building activity to only 100 units annually. As
a result, the City's growth in housing has declined by 95% since peaking in 1990.
Chart 6: City of San Bernardino
Housing Unit Growth (1990-1998)
2,000
1,750
1,500 []Housing Units Annexed
1,250 ❑Multi-family Permits
■Single-Family Permits
1,000
750
500
250
1990 1991 1992 1993 1994 1995 1996 1997
RHNA Evaluation
Page 6
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City of San Bernardino..
Alternative Growth Forecasts
SCAG's forecast explains only 73% of historical growth because it does not adequately reflect
the building boom of the early 1990s nor the ensuing slowdown. Because of this problem, CBA
forecasted the City's 2005 forecast based upon a logarithmic regression. A logarithmic (as
opposed to linear) equation more accurately takes into account the boom in housing and
household growth in the early 1990s, while accounting for the slowdown after 1994.
Chart 7 compares the accuracy of SCAG's initial household growth forecast with the City.
SCAG's linear regression forecast appears to explain a generally modest level (R2=73%)of past
building activity, with a 27% margin of error. An alternative forecast for 1998 through 2005
based upon logarithmic regression has a much higher level of accuracy(R2= 93%). Under this
scenario, the City can expect household growth of approximately 1,792 from 1998 to 2005.
The City's household growth forecast makes intuitive sense also. Assuming that housing growth
continues to increase at its present pace shown between 1994 and 1997, SCAG's forecast
appears to imply an extremely low vacancy rate by Year 2005. This would be unlikely given the
low level of building activity since 1994 and high vacancy rates discussed later. In any case, the
City believes that household growth will fall between 1,792 to 4,182 from 1998 through 2005.
Chart 7: City of San Bernardino
Alternative Growth Scenarios
65,000
HousinoTrend
SCAG's W=73%
62,500
Household Trend . _ .
60,000 . . _.. . ._ .. .
Ci s Rr=93%
57,500
55,000 I
1990 1992 1994 1996 1998 2000 2002 2004
RHNA Evalua8on
Page 8
City of San Bernardino
V. VACANCY ADJUSTMENT
Introduction
The second component of the Citys RHNA is the vacancy need adjustment. In brief, the
vacancy need adjustment is designed to ensure that a sufficient number of vacant units are
available to promote residential choice, moderate the cost of housing, and promote unit upkeep.
Thus, maintaining an appropriate number of vacancies in a community serves an important role
in regulating the supply, demand, and cost of housing in any given housing market.
SCAG calculates the City's vacancy adjustment based upon subregional averages for SANBAG.
The vacancy adjustment is set at the difference between the normal mobility rate found in the
1990 Census and current vacancies in 1998 as reported by DOF, plus an additional number of
vacant units to account for future housing growth. Based upon these calculations, the City has
an excess of 755 vacant units on the market, which are subtracted from the City's draft RHNA.
Pursuant to Section IIiB2b of the Appeals Process, a city may request "the substitution of a
different current vacancy rate or normal vacancy rate that meet all of the acceptability and
consistency criteria noted earlier for alternative data. Jurisdictions may also request that their
typical mobility or replacement rates be derived using (1) regional, (2) subregional, or (3) local
data, provided that one level of geography is more indicative of their housing market.
Data and Methodology
SCAG's use of the 1990 Census vacancy rates is not representative of the City. Year 1990
showed the highest housing unit growth, number of annexations, and building permit activity in
a decade. The City no longer expects such growth due to high vacancy rates, ending of federal
tax legislation, and a policy of not annexing additional land without County transfers of revenue.
Since 1994, the City shows a more predictable pattern in housing unit and household growth.
To provide alternative mobility and vacancy data, the City contracted with the Census Bureau
to examine the 1994 American Housing Survey ("AHS") for the Riverside-San Bernardino
region. A defined subarea was extracted for the City of San Bernardino and the corresponding
data on vacancies, tenure information and recent move-in data was collected. Appendix C
describes the American Housing Survey in more detail and how its meets SCAG's criteria.
CBA estimated the City's vacancy rate with idle electric meter data provided by Edison (SCE).
In the early 1990s, DOF used idle electric meter to estimate changes in the vacancy rate for
communities across California, but discontinued the practice in the early 1990s due to cost of
replicating the data statewide. Still, the use of idle meters as an vacancy estimation technique
is a widely accepted practice and is used by other cities (e.g., Burbank, Los Angeles, etc.).
RHNA Evaluation
Page 9
City of San Bernardino
Available Measures of Vacancy Rate
Four different measures of current vacancies and/or mobility rates are available: (1) the 1990
Census; (2) the 1994 American Housing Survey (also conducted by the Department of
Commerce); (3) Department of Finance (DOF) vacancy rates; and (4) Southern California
Edison data on idle electric meters. The first two measures are single point estimates, the third
is simply a slight adjustment of the 1990 Census vacancy rate, and the fourth measure tracks
vacancy rates over time. Each source of vacancy rates is described below:
1) 1990 Census. The 1990 Census is the definitive estimate of the City's mobility and
vacancy rate. In 1990, the City of San Bernardino had a vacancy rate of 7.4%. The
City's vacancy rate is calculated by the number of housing units on the market for rent
or sale divided by the total number of housing units. Units held for non year-round use
are not included. The Census Bureau has no recent update at the City level for 1998.
2) Department of Finance. The Department of Finance is required to update vacancy
rates annually. In the early 1990s, DOF used the percentage change in idle electric
meters over time as a multiplier to adjust the vacancy rates of all cities in California.
DOF discontinued this process during the mid 1990s, due to the cost of replicating the
data statewide. Now, DOF simply uses the unoccupied rate in the 1990 Census.
3) American Housing Survey. The American Housing Survey for the Riverside-San
Bernardino region is a statistically valid sample of housing units conducted by the
Census Bureau. A subset of the data is available for the City of San Bernardino. The
City's normal mobility rate and current vacancy rate is calculated as of 1994 using the
exact same methodology as the decennial census, which is used by the RHNA.
4) SCE/die Meters. SCE tracks idle electric meters as part of their overall operations.
DOF has used idle meters to estimate local vacancy rates because both have a strong
correlation over time. Specifically, DOF calculated the percentage change in idle electric
meters over time and applied it to the City's 1990 vacancy rate. These figures were then
used to adjust the City's official population estimates as well as subventions.
Although each source of vacancy rates has a different time frame or means of estimating
vacancies, what is important is that the story they tell is consistent over time. For instance, if
SCE data are to be accurate measures of the vacancy rate, as are the 1990 Census and 1994
AHS, each data source should provide results which are consistent over time. In other words,
the vacancy rate for 1994 should be the same according to AHS and SCE data.
RHNA Evaluation Page 10
City of San Bernardino
Calculating 1994 Vacancy Rate
Chart 8 calculates the City's current vacancy Chart 8: Trends in City Vacancy Rates
rate with information on SCE idle meters C01#1 col#2 Col#3 Col#4
and the 1990 Census. Chart 9 tracks the
percent of idle electric meters in San Year % Meters Percent Vacancy
Inactive Change Rate
Bernardino four 1990 through 1998 (Col. #2) 1990 1 7% — o
and percentage change over time Col. #3 . 7.4/o
( ) 1992 2.8% 70% 12.5%
Appendix D summarizes where the data is 7994 4.3% 159% 19.0%
derived from. The last column is derived by 1996 4.3% 159% 18.8%
multiplying the percent change in Column#3
1998 4.1% 147% 16.2%
by the vacancy rate in the 1990 Census.
Chart 9 compares the City's vacancy rates based upon the aforementioned four sources. What
is particularly surprising is the convergence and divergence. The massive shifts in the Inland
Economy shown earlier(e.g., building permits) have not been accounted for by DOF estimates.
DOF states that vacancy rates have not changed since 1990. Because this is contrary to
common sense, DOF clearly misrepresents the current level of vacancies in San Bernardino.
In contrast, SCE data are consistent with the 1990 Census and the 1994 AHS. SCE data shows
the City's vacancy rate climbed from 7.4% in 1990 to a peak of 19.0% in 1994 – which is
consistent with the 17.6% vacancy rate recorded by the AHS in 1994. Because the SCE and
AHS estimates are consistent, the AHS' direct measure of vacancies must be accurate - and
certainly more accurate than DOF's decade-old estimate.
Chart 9: City of San Bernardino
Estimation of Vacancy Rate (1990-1998)
25%
_Census/AHS Vat ncies
20% — 0 SCE-Derived Vacancy
- - -DOF Vacancy Rate
15%
10%
5%
0%
1990 1992 1994 1996 1998
RHNA Evaluation
Page 11
City of San Bernardino
Calculating 1998 Vacancy Rate
The previsous section established that SCE data on idle electric meters and the American
Housing Survey provide reliable estimates of the City's vacancy rate. They range from a high
low of 17.6% to a high of 19.0%. This contrasts sharply with DOF's estimate of only 7.6%.
Since the RHNA uses the 1998 vacancy rate as the basis for the vacancy need adjustment, the
question is what is the 1998 vacancy rate for the City of San Bernardino?
Correlation analysis can be used to help derive the City of San Bernardino's 1998 vacancy rate.
A comparison of vacancy rates and building permits show that both trends have a very high
correlation estimated at-91%. The high correlation means the following: (1) as vacancy rates
decline, building permits will increase, (2) as vacancy rates increase, building permits will
decline; and (3) if vacancy rates do not change neither will building permit activity.
Chart 10 illustrates the close relationship between vacancy trends and building permit activity.
For instance, rising vacancy rates led to a decline in building permit activity. The lowest building
permit activity correponded with the highest vacancy rates. However, the housing market
conditions in San Bernardino does not appear to have improved since 1994, because vacancy
rates have not declined nor has building permit activity improved during the same period.
Because building permit activity appears to have not changed along with SCE vacancy rates,
we can safety assume that the housing market is still in the same condition in 1998 as in 1994.
Therefore, the 1994 vacancy rate estimated by the Census Bureau for the AHS is probably the
most accurate measure of the level of vacancies currently in San Bernardino as of 1998.
Chart 10: City of San Bernardino
Building Permit and Vacancy Trends
1200
zs^r,
1000
20%
800
15% m
600 City Building fErrtiL
a • a• r-�` �EStireted vacancy Rate 10%
m 400 . .
200 . . . . _ `••� _ . . . . 5%
41
0 1 0%
1990 1991 1992 1993 1994 1995 1996 1997 1998
RHNA Evaluation
Page 12
City of San Bernardino
In summary, DOF provides an inaccurate measure of current vacancy rates as of 1998. This
is because DOF estimates that the City's vacancy rate has never changed over the decade.
This is impossible given the massive economic changes that have occurred in the Inland Empire
—such as the real estate crash, the closing of military bases, and rising vacancy rates—which
have impacted the City of San Bernardino as well as surrounding communities.
The current RHNA, if left unchanged, will require the City of San Bernardino to plan for housing
production that simply cannot occur during the 1998 through 2005 planning period. Current
vacancies are double the optimal rate of 5-6% for multifamily housing and 1.5-2.0% used by
SCAG during the last RHNA cycle. In short, developers will not construct new housing units
unless significant improvements are made in the underlying market demand ifor housing.
Because the draft RHNA relies extensively upon the vacancy need adjustment, it is critical to
obtain a measure which is more accurate than DOF's 10-year old estimate. This section has
shown that the AHS is a reliable estimate as supported by SCE data on idle electric meters.
Moreover, if DOF still used the same methodology they used in past years to update the City's
vcacancy rate, the City would have a significantly higher vacancy estimate of at least 17.5%.
Chart 11 summarizes three scenarios for calculating the City's current vacancy adjustment: (1)
SCAG's subregional and local defaults; (2) SCAG's local defaults based on the 1990 Census
and 1998 DOF; and (3) the City's most accurate RHNA based upon the 1994 AHS mobility rates
and 1998 updated vacancy rates. The third option is the preferred option for the City. It shows
that the City has a vacancy credit of 6,851 units that should be credited against their RHNA.
Chart 11: City of San Bernardino
Vacancy Need Calculation
=-1,250 Local Rates Local Rates
Calculation ased on 1990 based on the
Census 1994 AHS
Ideal Vacancies 2,248 2,756
Current Vacancies -398 :16U84
Balance (Ideal +Cur -1,250 -6,928 Future Vacancy Nee146 77 Net Vacancy Adjustm -1,104 -6,851
SOufCe: SCAG's RHNA Website;American Housing Survey, 1990 Census;Department or Finance
RHNA Evaluation
Page 13
City of San Bernardino
VI. HOUSING LOSS ADJUSTMENT
The third component of the RHNA is the housing loss adjustment. This adjustment is designed
to ensure that housing units that are lost to demolitions, mergers, conversions, or natural
disasters are replaced in the present planning period. The housing unit loss adjustment is an
important component of the RHNA, because housing unit losses are typically concentrated
among the oldest and most affordable component of a community's housing stock.
SCAG calculates the City's replacement rate based on subregional rates prepared for SANBAG.
The replacement rate is determined by calculating the average housing loss rate over a five year
period (1990 through 1994) which includes a regional multiplier to account for conversions of
housing to commercial or other non-housing uses. The City's average annual rate for housing
losses is then applied to the current number of units in the City and forecasted through 2005.
Pursuant to Section 111132b of the Appeals Process, a city may request "the substitution of a
different current vacancy rate or normal vacancy rate that meet all of the acceptability and
consistency criteria noted earlier for alternative data. Jurisdictions may also request that their
typical mobility or replacement rates be derived using (1) regional, (2) subregional, or(3) local
data, provided that one level of geography is more indicative of their housing market.
The City of San Bernardino is also requesting the use of local housing loss data to provide
consistency with our request to utilize local vacancy data. Moreover, local data is more
appropriate than subregional data, because local demolitions and conversions are subject to
discretionary processes that have little to do with surrounding communities. In fact, the City's
housing market is well established and tends to impact other jurisdictions, not vice-versa.
City staff compiled the total number of demolitions and conversions from 1990-1997 from
building permits and various planning-related applications for discretionary permits (next page).
The City also chose a different time, 1992 through 1996, to analyze the normal rate of housing
losses. This time period for analyzing housing unit losses was chosen because the midpoint is
1994 —the exact same year that the 1994 American Housing Survey was conducted.
The City's preliminary RHNA assumes that the City of San Bemardino lost approximately 171
units or an annual average units of 34 from 1990-1994. This translates into a replacement
requirement of 355 units from 1998 through 2005. Based upon the 1992-1996 period, the City
of San Bernardino actually lost 118 units or 24 units annually. After the requested local data and
time period is used, the City's housing unit loss adjustment should be 193 units.
RHNA Evaluation
Page 14
City of San Bernardino
CITY OF SAN BERNARDINO
DEVELOPMENT SERVICES DEPARTMENT- PLANNING DIVISION
MEMORANDUM
Date: December 7, 1999
To: Mark Hoffman, Project Manager, Cotton Beland Associates
From: Deborah Woldruff, Associate Planner
Re: RHNA Project - Demolitions and Conversions of Residential Units
cc: Margaret Park, Senior Planner; and, Joe Bellandi, Associate Planner
Per your request, the results of my research of City records is summarized below.
Demolitions of Residential Units:
1990 1991 1992 1993 1994 1995 1996 1997
40 units 22 units 16 units 6 units 20 units 120iniEs 145units 137units
Conversions of Residential Units to Commercial
1990 1991 1992 1993 1994 1995 1996 1997
0 units 1 unit 2 units 4 units 0 units 0 units 1 unit 0 units
Reductions of Residential Units
During the 10 year period, Building Plan Check staff recollect that reductions of residential
units (i.e., 3 units reduced to 2 units) occurred only sporadically, and resulted in a loss of 4 or
5 units.
Please feel free to contact me at (909) 384-5057 if you have any questions about this
information.
RHNA Evaluation
Page 15
City of San Bernardino
VII. Recalculation of RHNA
This Appeal has analyzed the Regional Housing Needs Assessment for San Bernardino for
1998 through 2005. This section briefly outlines the results of the analysis contained herein as
well as a menu of options from which negotiations for reductions can occur.
Household Growth: The prior sections found that SCAG's household growth forecast
appeared to be based on a straightline trend of occupied housing units from 1990 through
1998. However, we found that household growth between 1990-1993 was 13 times higher
than the volume experienced in 1994-1998. The disparity in growth forecast methodologies
produced estimates ranging from 4,182 (SCAG) to 1,792 (City) households by 2005.
Vacancy Credit Adjustment: SCAG's vacancy adjustment was based on 1990 Census.
In contrast, we used the American Housing Survey (AHS) and Edison (SCE) data to show
that vacancy levels in 1998 were 17.6% – over twice the 1998 rate of 7.5% stated by DOF.
When AHS data is used to also calculate the normal mobility rate, we found that the total
vacancy credit varied from a low of-755 (SCAG) to–6,851 (Edison and AHS data).
Housing Unit Loss Adjustment. Furthermore, the City also extracted, from their building
permit records, the history of demolitions and conversions over the past decade. The City
also chose the period of 1993-1997–a five year period around the 1994 AHS–as the most
representative of their housing market. Based on subsequent calculations, the City's housing
unit loss adjustment ranged from a high of 355 (SCAG) to a low of 193 units.
The aforementioned adjustments to SCAG's RHNA show a variety of alternatives. Chart 12
below summarizes the high and low estimates based upon the analysis contained in this report.
In brief, the RHNA estimates for the Year 2005 range from a high of 3,782 to a low of—4,866.
However, should a reallocation of household become necessary to satisfy HCD requirements,
the City would request that only the full vacancy and replacement adjustment be applied.
Chart 12: City's Recommended RHNA
RHNA Component [Al ocal Midpoint City Preferred
cation Estimate Estimate
Household Growth ,182 2 987 1 792 (1)* I Vacancy Adjustment 755 -3,833 -6851 (2)Housing Unit Loss 355 274 193 !31 Total ,782 -572 -4,866
Notes:
1.City's forecast based upon logistic regression of growth from 1990-1998.
2.Based upon American Housing Survey data verified by Edison data
3.Based upon local building permit data, including conversions
RHNA Evaluation
Page 16
City of San Bemardino
Figure 2
RHNA Worksheet
City of San Bernardino
RHNADefault L Default L;9RHNA_-i LocaCen Census
Household Growth
1998 Housing Units 64,236 64,236 64,236 64,236
-%Single Family 60.3%, 60.3% 60.3% 60.3%
- %Multifamily 39.7% 39.7% 39.7% 39.7%,
Households
-- 1990 Census 54,635 54,635 54,635 54.635
-- 1998 D.O.F. 59,208 59,208 59,208 59,208
--2005 Projection 63,390 63,390 61,000 61,000
--Total Growth 4,182 4,182 1 1 1,792 1 1,792
Vacancy Data
%UnOccupied (1998) 7.8% 7.8% 17.6% 17.6%
Total Renters n.a. 26,014 21,100 26,014
Recent Move-ins n.a. 12,943 12,250 12,943
Vacant for Rent n.a. 2,406 7,100 2,406
Total Owners n.a. 28.468 28,100 28,468
Recent Move-ins n.a. 3,063 4,250 3,063
Vacant for Sale n.a. 600 1,900 600
Other Vacants n.a. 1,316 1.500 1,316
Mobility Rates
For Owners n.a. 1.4% 2.0%, 1.4%
For Rentals n.a, ,o
6.6/ 7.7% 6.6
Total Mobility n.a. 3.9% 4.5% 3,9%,
Effective Vacancy nA. 69.6% 85.7%
69.6
Vacancy Needs
1. Ideal Vacants-All 2,575 2,248 2,756 E7.858
2. Current Vacants 3,497 3_4_98 9.684 3.Surplus or Deficit 922 -1,250 -6,928 4. Future Vacancies 168 146 77 S.Vacancy Need _754 i -1.104 -6.851
Housing Unit Loss
1998 Total Units n.a 64,236 64,236 E58,804
1990 Housing Units n.a 58,804 58,804
Housing Losses n a 171 118 Annual Loss 34.20 23.60 n.a Loss Rate 0.00074 0.000582 0.000401 Projected Losses 355 280 193
RHNA Calculation
Household Growth 4,182 4,182 1,792 1,792
Vacancy Need -755 1,104 -6,851
Demolitions 58 5.547
Total Housing Need 3.782 »� ->�
3,358 -4,866 3,562
RHNA Evaluation
Page 17
City of San Bernardino
VIII. REALLOCATION OF HOUSING KNITS
If San Bernardino's RHNA is reduced as authorized by State law, the issue remains as to the
disposition of the housing units. According to SCAG's appeals policies and procedures, the
Regional Council is authorized to reallocate the household growth or simply reduce the need for
the subregion if the appeal justifies that decision.
In making that decision of whether or not to reallocate units, we understand that SCAG is
required by the State of California Department of Housing and Community Development (HCD)
to meet a minimum level of construction need for the planning period of 1998 through 2005. In
recognition that growth forecasts are more accurate at the local level, HCD has shown flexibility
in lowering the initial regional growth forecasts by approximately 30,000 households.
In light of this flexibility for making adjustments where strong technical justification is provided,
we believe that reductions in household growth forecasts in San Bernardino should not be
reallocated to neighboring communities for legal, practical, and financial reasons.
1. SCAG staff has consistently stated at the Regional Housing Needs Workshop,
the HCD Workshop, and other subregional venues that jurisdictions satisfied with
their RHNA's can immediately complete their Housing Elements.
2. Many jurisdictions have already completed their analysis of adequate sites to
address their RHNA allocation and are submitting their housing elements now
to the State Department of Housing and Community Development.
3. A reallocation of units to other jurisdictions that have accurate RHNAs would
cause their RHNA to increase well after the statutory deadline for filing appeals
has Passed, thereby denying them adequate due process.
4. A reallocation of units, especially in larger County unincorporated areas, would
invalidate the current housing unit allocations of smaller jurisdictions within a
County, thus necessitating a reopening of the entire growth forecast.
5. Any potential reallocation of units would not be finalized until July 2000 —after
the statutory deadline for Housing Elements, thereby resulting in significant delay
for every jurisdiction in the SCAG region.
Any reallocation of housing units could have a detrimental impact throughout the SCAG region.
Reallocation could potentially cause additional financial burden as communities scramble to
prepare housing element amendments, further delay submission of housing elements, and
erode the credibility of the RHNA and growth forecast process. Finally, State law requires a
meaningful appeal process with adequate due process for all affected communities. Any
reallocation would be contrary to these stated goals and may result in unnecessary litigation.
RHNA Evalua6'on
Page fa
City of San Bernardino
Appendix A:
Annexation Log
Annexation Resolution ! LAFCO Square Census
No. Number No. (Effective Date Miles Acres Tract
340 89-329 2541 09/05/1989 0.03 21.1 65
341 90-39 j 2570 02/15/1990 0.00 0.6 45.02
342 j 90-380 2599 09/28/1990 0.65 415.01 72
343 94-09 2758 I 01/31/1994 2.03 1,301.81 27
344 FAILED 2781
345 90-488 2620 01/02/1991 0.04 25.8 63
346 91-07 2621 j 01/23/1991 I 0.06 36.51 74.05
347 91-57 2584 03/14/1991 0.04 27.8 61 or 110
348 91-138 2643 j 04/19/1991 0.06 39.1 ! 61
349 DEFEATED 2632 j
350 DEFEATED 2671
351 91-60 2644 03/0411991 1 0.36 j 230.0 72
352 91-438 2672 11/12/1991 I 0.09 55.7 1 64
353 91-466 2684 11/26/1991 0.07 j 45.7 52
354 92-239 2743 j 08/04/1993 0.04 24.4 ! 65
355 92-279 2713 07/24/1992 0.10 65.0 j 65
356 94-37 2760 03/09/1994 0.03 20.0 45.02
TOTAL j 3.61 1 2,308.6 j
RHNA Evaluation -
Page 19
City of San Bernardino
Appendix B:
Housing and Household Growth
DOF Estimates Building Permits Other Losses/Gains
F Housing Households Total Single- Multi- Housing Units
Units Famil Famil Losses Annexed
n.a. n.a. 208 145 63
. . n.a n.a. n.a. 595 311 284 n.a. n.a.
n.a. n.a. 188 108 80
n.a. n.a.
1983 n.a. n.a. 1,160 736 424
n.a. n.a.
1984 n.a. n.a. 3,250 736 2514
n.a. n.a.
1985 n.a. n.a. 1,492 306 1,186 n.a. n.a.
1986 n.a. n.a. 3,087 661 2,426 n.a. n.a.
1987 n.a. n.a. 1,164 681 483 n.a. n.a.
1988 n.a. n.a. 296 292 4 n.a. n.a.
1989 n.a. n.a. 1,011 659 352 n.a. n.a.
1990 58,969 54,635 1,952 848 202 40 902
1991 61,336 56,827 1,470 412 28 23 1,030
1992 62,575 57,930 569 368 72 18 129
1993 63,223 58,514 674 297 248 10 129
1994 63,593 58,857 173 171 2 20 0
1995 63,966 59,102 98 98 0 20 0
1996 64,059 59,188 97 97 0 46 0
1997 64,170 59,147 109 109 0 37 0
1998 1 64,236 59,208 137 137 0 150 0
R MA Evaluation
Page 20
City of San Bernardino
Appendix C:
1994 American Housing Survey
This appeal relies heavily upon data from the 1994 American Housing Survey for the Riverside-
San Bernardino region. It is prepared every five years and represents the most statistically
reliable picture of housing market conditions through out the region. It is important to note its
advantages when judging whether it is more reliable than data sources currently used by the
RHNA. Pursuant to the appeals procedure, the AHS exhibits the following superior qualities:
(1)Availability The American Housing Survey("AHS") is generally accessible to the
public and is not constrained for use by proprietary conditions or other conditions
rendering them difficult to obtain or process. The data is free to the public and may be
obtained at libraries with local government holdings or for free on the internet.
(2)Accurate: The AHS is clearly an accurate and statistically valid sample for the City
of San Bernardino. In contrast to the Census, the AHS is done by personal interview,
with interviewers following up in person which each of those surveyed respondents.
Much of the decennial Census is done through filling out forms with much less followup.
Being prepared by the U.S. Department of Commerce, the AHS also exhibits a high
standard in statistical rigor demanded itself by the Census Bureau.
Current data sources used for the RHNA are less accurate. For instance, the current
DOF vacancy data is inaccurate—being ten years old and merely an extrapolation of the
1990 Census to the present. Since the 1990 Census, the DOF vacancy rate has never
changed, although mid census surveys (e.g., the AHS)and private vendor surveys (e.g.,
RealFacts) record massive shifts in vacancy rates. local permit data also supports this
trend —showing huge declines in building permits as vacancy levels have soared.
(3) Current: The 1994 AHS is more recent than existing 1990 data sets and portrays
local conditions in a more accurate and representative fashion. For instance, building
permit data show that construction levels have dramatically fallen off in recent years.
This is largely a function of dampened housing demand reflected by the vacancy rate.
The AHS shows the vacancy rates to be extremely high in 1994 at the same time.
Since building permit levels have remained the same since 1994, we can assume that
underlying vacancy rates which fueled housing demand are still low.
(4) Reolicable: The data can be reproduced in several larger jurisdictions and lend
themselves to widespread application to a housing market area larger than a single
jurisdiction, in this case the County of San Bernardino (SANBAG). Although not
reproducible for smaller jurisdictions due to sampling variability, the appeals procedures
do not specify nor require that the data must be reproducible in all communities.
RIiNA Evaluation
Page 21
City of San Bernardino
Appendix D:
Sample Edison Worksheet
ELECTRIC METER COUNT, Edison Districts,
As of March 1998
0 s.y.uO h Meer um
M..e.r a M ywe I M,IwR d r .a y«u..la.
Tm N.m. $V TOW Normal S. TOW TOW Nvm41 5r Tul Nmvl L T.
EM Dw91C4 umr>t 11 14. M A IJ�% bN% Sl..s Ne Ne be 1 % N % Id%
6vlOr 10,150 SA 4 511 u 0.0 52 2.08 381 J W 18.0 0.1 18.1
V . 74.= 27]8 115 z881 J] 02 39 9,]81 817 7 824 67 0.1 a
6d� 124]]8 19]1 288 2219 10 02 1A 15.915 1.198 J 1,1W 0.3 0.0 17
R. 104.713 105] w 1118 J2 at JJ Js.m 4ee 5 471 1.3 0.0 1.3
S'^B.EO'.4rMM 127,W 2991 JB ].027 Z7 0.0 21 72105 1.410 J tat] 44 0.0 4.4
29 Prr. ZZ298 1,425 s tq 6.4 0.0 84 2821 2K 0 254 9.0 00 90
To 5.18.m. m,415 1z97J 5[1 17.516 28 0.1 2.9 119089 4527 21 1,548 JA 00 38
Tt1.u.m p.y 11zt5e m 11e sm 0. at as 1194 175 2 M is 110 LS
�•+ 98.154 611 1a1 716 0.e 0.1 07 ]..882 50) 4 511 15 0.0 1.5
T"V• 208,712 1,088 219 1.265 0.5 01 05 tle25 682 a 688 1.5 00 15
Say 8. 45,1M 141 5 1K 0.7 0.0 aJ 22699 1961 1 200 0.9 0.0 0.9
T.W ft z426418 ]B,BBJ 1,611 0gJ04 15 01 1.8 904,517 25,812 107 25919 Z9 a0 29
'°'°. S.Yy01 C891.0a Ea9.1 C.1prry.
RHHA Eveluatlon
Page 22
So Calif Assn of Gov 3/23/00 4 :03 : PAGE 2/5 RightFAX
ATTACHMENT 2
To: San Bernardino County Jurisdictions
From: RHNA Staff
Date: March 23,2000
RE: Preliminary Recommendations and Analysis on Delegate Appeals
NOTE: On March 15, the jurisdictions in San Bernardino County held a mediated `Meet and Confer" session
pertaining to the four appeals of the Draft Regional Housing Needs Assessment filed in the subregion. At the
session, participants requested that SCAG document its analysis and recommendations on the appeals. This
memo has been prepared in response to that request. The following is the analysis and recommendations for
each appeal, followed by the standard checklist used to measure requests for changes to the Household
Growth component of need.
Appellate Jurisdiction: Chino Hills
Preliminary Staff Recommendation: Reject
Analysis:
Basis for Appeal:
The jurisdiction is seeking a reduction in household growth, vacancy need, and replacement.
The basis for the household growth reduction is a local analysis of past building trends, plus an
accounting of build-out capacity under the general plan. The reduction in replacement need is
based on the general high quality of housing stock.
Basis for Staff Recommendation:
The requested household growth estimate did not meet standard input parameters for SCAG
growth forecast This analysis is based on a comparison of the jurisdiction's request to long-term
Vend data (see attached checklist). The jurisdiction did not submit alternative data meeting the
data substitution criteria set forth in the RHNA appeals procedures, particularly that substitute
data be consistent with accepted methodology. Further, reductions are justified in the appeal on
current zoning and growth control, both clearly excluded from consideration under State housing
taw.
Appellate Jurisdiction: San Bernardino (City)
Preliminary Staff Recommendation: Reject
Analysis:
Basis for Appeal:
The jurisdiction is seeking a reduction in household growth, vacancy need, and replacement
need. The basis for the household growth reduction is a local analysis of past building trends,
along with regression analysis. The reduction in vacancy need is based on substitution of
existing vacancy data from the 1994 American Housing Survey. The replacement need request
is a based on a substitution of demolition permit records from the period 1992-96.
#3,P)67%,]-san Itrila aroil��i d
app®h
SOUTHERN CALIFORNIA
ASSOCIATION of GOVERNMENTS
So Calif Assn of Gov 3/23/00 4 : 03 : PAGE 3/5 RightFAX
Basis for Staff Recommendation:
The requested household growth estimate did not meet standard input parameters for SCAG
growth forecast(see attached checklist). The substitution of vacancy data from the American
Housing Survey does not meet the criteria for alternative data, as it not available for all
jurisdictions in the region. Further, its reliability for a baseline vacancy estimate is questionable
due to a small sample size, and survey having been taken at the lowest point in the region's
housing market recession. The replacement need requests seeks an alternative sample period
that is not inclusive of the default sample taken for the region, and does not demonstrate that the
data requested is a better,as opposed to preferable, representation of conditions.
Appellate Jurisdiction: San Bemardino(County)
Preliminary Staff Recommendation: Reject pending voluntary redistribution
Analysis:
Basis for Appeal:
The jurisdiction is seeking a reduction in household growth and vacancy need. The household
growth request is primarily based on policy considerations, including distribution between
incorporated and unincorporated jurisdictions, as well as ability to provide services to new
residents. Vacancy request is based on assertion that "effective vacancy' is higher than
reflected in default data.
Basis for Staff Recommendation:
The input for a revised 2005 household estimate met the parameters for household growth input
based on analysis of long tern trends (see attached checklist). Staff accepted input contingent
upon redistribution to other jurisdictions, as the county had based its claim for lower growth on
comparison with incorporated cities. Vacancy request was not accepted due to lack of reliable
or measurable data, meeting the data substitution criteria, that could be used in the calculation
methodology.
Appellate Jurisdiction: Victorville
Preliminary Staff Recommendation: Reject pending further input
Analysis:
Basis for Appeal:
The jurisdiction is seeking a reduction in household growth. The reduction is based on past
building trends,and claims that growth trends are amplified by past annexations.
Basis for Staff Recommendation:
#341967vI-5"hmi urmt,3A of
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SOUTHERN CALIFORNIA
ASSOCIATION of GOVERNMENTS
So Calif Assn of Gov 3123/00 4 :03 : PAGE 4/5 HightFAX
The requested household growth estimate did not meet standard input parameters for SCAG
growth forecast (see checklist attached). Staff allowed opportunity for further clarification on
documentation on this appeal. THE APPEAL WAS WITHDRAWN BY THE JURISDICTION.
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SOUTHERN CALIFORNIA
ASSOCIATION of GOVERNMENTS
So Calif Assn of Gov 3/23/00 4 :03 : PAGE 5/5 RightFAX
City Appeal and Review Checklist for Household Growth (hlput Parameters)
A. City Appeal: 1998 estimate or 2005 adopted
B. Basis for Appeal:
Review
A. 1998 estimate:
B. 2005 adopted:
Time span for analysis
Criteria l: past growth trend and current ratio
1-1. Trend extrapolation: extrapolation of the past growth of households using the linear trend.
1-2. Ratio trend: extrapolation of city's past share of county's household using the linear trend.
1-3. Current ratio: use of the current city's share of county household.
1-4. The average of results of the above three methods is compared with the adopted 2005 household.
2-1. If the average is lower than the adopted 2005 household,the average is compared with the suggested
city input.
2-2. If comparison results in less than 1%point difference, accept the city input.
2-3. If comparison results in more than 1%point difference,use adopted household.
3-1. If the average is higher than the adopted 2005 household, the adopted 2005 household is compared
with the suggested city input.
3-2. If comparison results in less than 1%point difference, accept the city input.
3-3. If comparison results in more than 1%point difference, use adopted household.
Criteria 2: others
C. Recommendation
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SOUTHERN CALIFORNIA
ASSOCIATION of GOVERNMENTS
1 RESOLUTION NO.
2 RESOLUTION OF THE CITY OF SAN BERNARDINO OBJECTING TO THE
3 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS' REGIONAL
HOUSING NEEDS ASSESSMENT PROCESS FOR ESTABLISHING HOUSING
4 CONSTRUCTION TARGETS.
5 (a) WHEREAS, the Southern California Association of Governments (SCAG) is
6
7 responsible for preparing the Regional Housing Needs Assessment (RHNA), which identifies
8 regional, subregional and local targets for the amount and type of housing needed during the
9 current planning period (1998 - 2005).
10 (b) WHEREAS, the timing of the current RHNA planning period has required SCAG
11
to use outdated and inaccurate 1990 Census data to make housing needs projections for
12
1998-2005.
13
14 (c) WHEREAS, SCAG adopted a Draft RHNA in November 1999, with provisions for
15 local jurisdictions to appeal the existing need assessments or the construction need allocations
16 by February 1, 2000.
17
(d) WHEREAS, the City of San Bernardino filed an appeal of its RHNA on the basis
18
19 that the vacancy rate was too low, the housing unit loss was too low, and the household growth
20 rate was too high.
21 (e) WHEREAS, the SANBAG member jurisdiction appeals have demonstrated flaws in
22 the RHNA data with actual recessionary growth data from the 1990's.
23
24 (f) WHEREAS, SCAG staff is not recommending approval of the City's RHNA appeal,
25 due partly to a failure to recognize the lagging economic recovery in the Inland Empire and
26 partly to rigid adherence to the policy of maintaining the RHNA targets for each subregion
27 (subregional caps).
28
1
1 (g) WHEREAS, acceptance of any SANBAG member appeals will result in a
2 reallocation of units to other jurisdictions within the SANBAG subregion.
3
4 NOW, THEREFORE, BE IT RESOLVED, FOUND, AND DETERMINED by the
5 Mayor and Common Council that the SANBAG Board of Directors petition the SCAG
6 Regional Council to:
7 1. ACCEPT all RHNA appeals from the SANBAG subregion.
8 2. DISREGARD the target cap proposed for the SANBAG subregion.
9
10 3. DISREGARD the zero-sum policy of reallocating excess units within the SANBAG
11 subregion.
12 4. RE-ADDRESS the regional growth target with the State Department of Housing and
13 Community Development, supporting a reduction as needed to adjust for RHNA
14
appeals from the SANBAG subregion.
15
16 BE IT FURTHER RESOLVED by the Mayor and Common Council of the City of San
17 Bernardino that:
18 The projected growth poses a dramatic challenge for San Bernardino County leaders in
19 that it will increase the need for all forms of public and private sector goods and services.
20
21 These needs and services could overwhelm public resources if growth is not managed wisely,
22 and with vision. These needs include schools, parks and open spaces, and the provision of
23 adequate, cost-effective systems of water, electricity, and transportation.
24
25
26
27
28
2
1 RESOLUTION . . . OBJECTING TO THE SOUTHERN CALIFORNIA
2 ASSOCIATION OF GOVERNMENTS' REGIONAL HOUSING NEEDS ASSESSMENT
PROCESS FOR ESTABLISHING HOUSING CONSTRUCTION TARGETS.
3
4 I HEREBY CERTIFY that the foregoing resolution was duly adopted by the Mayor and
5 Common Council of the City of San Bernardino at a meeting theretf,
6 held on the day of 2000, by the following vote, to wit:
7
8 Council Members AYES NAYS ABSTAIN ABSENT
9 ESTRADA
10 LIEN
11 MCGINNIS
12
SCHNETZ
13
14 SUAREZ
15 ANDERSON
16 MCCAMMACK
17
18
City Clerk
19
20 The foregoing resolution is hereby approved this day of
21 2000.
22 JUDITH VALLES, Mayor
23 City of San Bernardino
Approved as to form
24 and legal content:
25 JAMES F. ENMAN
26 City Art e
27 By:
28
3