Most local governments in California have finalized their 2021–2029/2022–2030 housing plans. These plans must identify parcels with capacity to add new housing, and unlike previous plans, state law now mandates that they affirmatively further fair housing. State guidelines suggest that local governments identify or create capacity for new housing, especially for low-income households, in high-opportunity neighborhoods. In this report, we assess whether local governments followed these guidelines by analyzing the site inventories adopted by 199 California cities before April 2024. We do this using the Fair Housing Land Use Score (FHLUS), which measures the distribution of housing sites by neighborhood opportunity, using metrics such as household incomes and environmental quality. We can thereby answer the question, are cities meeting their fair housing obligations? The answer is no. Most cities (roughly 80%) disproportionately plan for new housing in their least affluent neighborhoods and those with worse environmental quality, and sites designated for low-income housing are less likely to be in high-opportunity neighborhoods than sites for above moderate-income households. One positive finding is that sites proposed in rezoning plans are better located than non-rezoned sites, even though they are a minority of sites. In addition to reporting the FHLUS, we provide preliminary evidence of whether certain kinds of cities — e.g., bigger, more affluent, or more equal cities — did better at planning for housing in their high-opportunity neighborhoods. We find no significant correlations between cities’ socioeconomic or other characteristics and their FHLUS. The one factor associated with the FHLUS is the spatial distribution of existing zoning: Cities mostly identify sites for new multifamily housing near existing multifamily housing, suggesting an important role for inertia in housing plans. Our findings illustrate how rules for site selection maintain the status quo and demonstrate that unless the state requires new housing sites be created in high-opportunity neighborhoods, California cities will not affirmatively further fair housing.

A 2018 California law requires local governments to affirmatively further fair housing (AFFH) in their General Plan’s housing element. This paper examines how eight municipalities reacted to this requirement in three areas of their 2021 plans: the analysis of fair housing issues, proposed fair housing programs, and the location of sites identified for low-income housing development. We consider whether these cities’ over 200 fair housing programs are meaningful actions by evaluating their potential impact, and measure the distribution of proposed sites for new low-income housing across neighborhoods. The cities created many new programs in response to the mandate; however, most programs do not meaningfully advance fair housing goals. Moreover, most cities do not modify land-use plans to allow affordable housing in affluent neighborhoods. Additionally, we find a mismatch in the plans. The affluent, majority-white cities that developed more meaningful fair housing programs continued to concentrate sites for affordable housing in their least affluent neighborhoods. Our analysis of potential program impact allows us to identify AFFH oversight challenges and make recommendations for AFFH guidelines. We focus on California, but the research is relevant to federal AFFH implementation and raises questions about how to best advance fair housing goals.