The Housing Element is one of many elements, or chapters, of the City’s General Plan—the long-term roadmap for the City’s future and development.  The Housing Element must be updated every 8 years and shows the locations where housing can be built, and the policies and strategies necessary to meet the community’s housing needs. It is the only element of the General Plan subject to State requirements for content and which must be approved by the State Housing and Community Development Department (HCD).

The City could face legal challenges to its zoning requirements and decisions, which would require city resources to address.  In some cases, judges have suspended the local agency’s ability to issue building permits until the Housing Element is certified. It would also make the City ineligible for many State grants and funding programs, that provide critical funding sources for affordable housing and transportation improvements.

The State of California determines the number of homes that are needed for the Bay Area. The Association of Bay Area Governments (ABAG) then distributes this information, the regional need, for the nine Bay Area counties.  Each city and county is assigned a portion of the regional need based on considerations such as future population, access to jobs, and other factors. This assignment is known as the Regional Housing Needs Allocation (RHNA), and is intended to promote the following objectives: 

• Increase the housing supply and the mix of housing types in an equitable manner
• Promote infill development, efficient development, and Greenhouse Gas reduction
• Promote better relationship between jobs and housing, particularly jobs-housing fit    
• Balance existing disproportionate geographic concentrations of income categories
• Affirmatively further fair housing

Each jurisdiction must show there is enough land zoned for housing to accommodate future population growth.

ABAG formed a methodology committee to determine how the need for future housing should be distributed among jurisdictions. The Committee included local elected officials and staff representing every county, as well as regional stakeholders to facilitate sharing of diverse perspectives, and met from October 2019 to December 2020. The Plan Bay Area 2050 Blueprint model was chosen as the starting point, or baseline.  For technical details and meeting reports (https://abag.ca.gov/our-work/housing/rhna-regional-housing-needs-allocation/housing-methodology-committee ).

With a projected growth of over 441,000 households for the Bay Area by 2030, San Mateo County was assigned 10.8% of the Bay Area RHNA.  Currently the County has 9.4 % of the current population, 10% of the jobs and is estimated to have 10% of the future population.

The RHNA for any given city was primarily based on projected number of households.  The baseline is adjusted by factors including proximity to jobs, and high resource areas that have excellent access to amenities such as good schools and employment centers.

Even though San Mateo does not have the largest population, it has the most households of any city in San Mateo County, and that is the main reason it has the largest RHNA. The household base was then adjusted by the other factors mentioned above, which further increased the RHNA. In particular, San Mateo has a high share of households in high resource areas and good access to jobs.

The methodology was adopted in January and will be submitted to the State HCD for review.  The State will review it to ensure it meets statutory objectives. Once that is completed, ABAG will announce the allocations in Spring 2021 as well as the guidelines for an appeals process during summer/fall, and release the final RHNA in late 2021. Now that the methodology has been adopted appeals can only be granted based on limited criteria as described in Government Code Section 65584.05. For example, appeals must demonstrate that ABAG did not adequately consider information provided during the methodology process, did not use a methodology that meets the State criteria, or that some unforeseen change in circumstances has occurred since the methodology was finalized.  Since ABAG conducted a year-long public process developing the methodology that incorporates all of the State requirements, it’s unlikely that an appeal of the methodology ABAG used would be granted. Recently, only 2 out of 52 appeals from Southern California jurisdictions were partially approved due to errors based on boundaries and flood plain designations. It is not possible to challenge the overall number for the Bay Area at this time.

The new RHNA cycle covers the years 2023-2031. The General Plan update period covers up to the year 2040 which spans two Housing Element cycles.  At the very least, General Plan 2040 will need to ensure that enough land is zoned for housing for RHNA 2023-31.

The City will evaluate the current zoning of potential sites for housing but may need to consider zoning revisions to accommodate the RHNA. The General Plan Update process will establish the areas where new development should be encouraged through the Land Use Element.  This process is underway and includes robust community engagement. Several study areas have been identified to evaluate where future residential development should be prioritized.  If the next General Plan update does not also account for the following RHNA, 2031-2039, General Plan 2040 would need to be further updated to account for the next cycle. More information is available on the General Plan Update website (https://strivesanmateo.org/).

Measure Y was approved by voters in November 2020 and sets limits on new residential building heights and densities.  The City needs to evaluate how much housing can built within the limits of Measure Y to determine whether the City is able to meet its RHNA under the current restrictions.  This analysis is underway and requires looking at every parcel that can accommodate housing within city limits that meets the eligibility criteria under Housing Element law.

The City must ensure that the appropriate zoning is in place to accommodate RHNA but does not control when or how much housing is actually built.  New housing construction is based on a variety of socio-economic factors such as demand, available financing, land and construction costs, etc. and is ultimately driven by private property owners.