In 2015, the Cities Association of Santa Clara County identified study of a potential RHNA Subregion as a priority.
What is a RHNA Subregion? Every jurisdiction receives a Regional Housing Needs Allocation (RHNA) that determines the number of new housing units it needs to plan for in its Housing Element. Typically those numbers are provided to each jurisdiction by the local Council of Governments– in the Bay Area’s case, the Association of Bay Area Governments (ABAG). However, State law allows jurisdictions to band together to form a subregion where they can conduct an allocation process that parallels, but is separate from, the process conducted by ABAG.
A RHNA subregion does not relieve a city of its responsibility to address its housing need. It also does not require that a city take on higher goals than it is willing to accept. The main benefit of a subregion is that cities work collectively to establish goals, and that by working together they are thinking about housing development regionally. San Mateo, Solano, and Napa Counties all have adopted a subregion.
SV@Home assisted the Cities Association in pulling together a task force that has been meeting regularly to discuss the potential and to develop guiding principles and a potential plan for implementation. Earlier this summer, the Santa Clara Civil Grand Jury Report included a recommendation that all cities agree to form a RHNA subregion. The report stated that the trading of RHNA requirements between cities could lead to more strategic development, based on differing capacities in cities. In response to the Grand Jury report, all cities are required to respond to this recommendation.
Current City Council discussions have focused on expressing interest, and not formally joining a sub-region at this time. Overall, local officials are interested in the idea of having more conversation, but skeptical if these talks will lead to concrete results. The ability to collaborate on more than just RHNA allocation through the sub-region process is also intriguing to some officials. The Cities Association continues to work with its member cities to determine potential action.
Cities who have responded to the Cities Association expressing interest are: Saratoga, Los Gatos, San Jose, Campbell, Los Altos, Palo Alto, Cupertino, Gilroy, and Morgan Hill.
SV@Home continues to support the formation of a RHNA Subregion in Santa Clara County. Local jurisdictions continue to fall behind in meeting their RHNA goals, especially for housing affordable to lower and moderate income households, and additional coordination and cooperation among cities can help produce results.Participation in a sub-region allows cities a new tool to address the regional housing crisis in an innovative way. Based on current reactions from local officials, more must be done to address the concerns of our diverse cities by confirming a clear, productive framework for cooperation.