Regional Affordable Housing Benchmarks to Become Official This Week

At its meeting Wednesday, the Planning Commission will receive an update on near impossible affordable housing benchmarks set by the state in its regional Housing Needs Assessment (RHNA).

According to draft projections released earlier this month at a meeting of the City Council’s Legislative Policy Committee, the city must guarantee it can build 9,409 units of housing between 2021 and 2029 based on Zoning Code provisions and land use ordinances.

According to the numbers, the city must produce 2,739 very-low-income units, 1,659 low-income units, 1,562 moderate-income units, and 3,449 above-moderate-income units.

That number is up from the 2014-2019 cycle when the city was required to plan for 1,332 units, a benchmark it also did not come close to hitting.

City officials have expressed concern over the numbers, which are expected to become official this week.
According to Planning Director David Reyes, no city in the region will be able to meet their numbers. The city is looking for ways to appeal the numbers after the official projections are released this week.

“It’s almost double the number of the last cycle,” Reyes told the city’s Legislative Policy Committee last month. “It will be a daunting challenge. The planning won’t be challenging. It’s whether or not we are going to produce those units. The state is penalizing jurisdictions that don’t produce units. Before it was about planning, but now it is about producing.”

The process, which allows cities to appeal up to 45 days after the numbers are released, includes an opportunity for a public hearing. However, that process is even murkier this year. Cities can appeal numbers assigned to other jurisdictions. And even if the appeal is successful, the projected housing needs will be shifted to another city, which means Pasadena’s numbers could increase.

Reyes said the city is hoping for a miscalculation. Mayor Terry Tornek said the city may have to consider a legislative approach in its response if it cannot successfully appeal the projections.

The Planning Commission could forward a recommendation to the City Council. The council will receive a report on the projections after the official numbers are released.

The city is experiencing a severe affordable housing shortage as local rents continue to increase and some apartments now rent for more than $3,000 a month.

The state-mandated city housing element is part of the General Plan and must be updated every four to eight years to address the city’s current and projected housing needs.

As part of that element, the state allocates housing numbers, but the city is not required to construct the RHNA housing. Instead, each jurisdiction is required to plan for the new housing units by providing appropriate zoning with adequate density to accommodate the number of new units in its RHNA target.

Pasadena has the zoning laws in place to plan to meet the projected benchmark. In the past, the numbers were determined by a local jurisdiction’s growth forecast and included zoning codes, the General Plan, and other factors for growth. Those numbers are still important, but now the state is also considering jobs and transit, which means Pasadena’s numbers have increased due to its growth.

Senate Bill 35, which became law in 2018, allows developers to skip parts of the city’s development process and overrides zoning laws depending on how far jurisdictions fall short in their RHNA numbers.

Projects could be streamlined, exempted from The California Environmental Quality Act, CEQA, which generally requires state and local government agencies to inform decision-makers and the public about potential environmental impacts of proposed projects, and only come up for scrutiny under the city’s design review process.

“Given our progress in the last cycle, no matter what our land use may permit, there is no way we are going to approach the production designated in the new cycle,” Tornek said after the draft numbers were released.