How Fair is Fair-Share? A Longitudinal Assessment of California’s Housing Element Law
The state of California implements the Regional Housing Needs Assessment (RHNA) program as the central pillar of its statewide housing policy, the Housing Element Law. It determines “fair share” allocations of a region’s forecasted growth in households for each city and county, and directs local jurisdictions to accommodate the allocations in its general plans and zoning capacity.
The RHNA process is an attempt to ensure that additional housing units are constructed to accommodate population growth in every part of the state. However, nearly forty years since RHNA was first established, California today faces a housing crisis where vacancy rates are very low and rent and ownership prices have skyrocketed, especially in its coastal metropolitan regions (Alamo and Uhler 2015). While limited studies of the RHNA program have been conducted in the past, none have examined it from a comprehensive and longitudinal perspective.
I analyzed data on RHNA allocations and performance for the Southern California Association of Governments (SCAG), a regional Council of Governments that encompasses six counties and is the most populous in the state. Covering the period from 1998 to 2021, I found that high allocations are strongly associated with cities that have lower household incomes, more people of color, and are farther away from downtown Los Angeles. They are also associated with cities having high rates of past household growth. In contrast, housing production was associated only with past household growth and distance from downtown Los Angeles.
I conclude that SCAG’s implementation of RHNA reinforces racial and economic disparities of housing growth in the region. I also find that it has a recursive effect over time, maintaining high allocations for cities on the urban fringe while rewarding slow-growth cities with low allocations. The RHNA implementation by the Association of Bay Area Governments (ABAG) displays similar dynamics of disparity (Bromfield and Moore 2017). Major changes to RHNA allocation methodologies are necessary to address these structural inequalities in California’s housing landscape.