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Exaggerated RHNA figures:

  • The inflated premise of 2 million housing units sets the stage for flawed RHNA figures, particularly the allocation of over 82,000 units for San Francisco by 2031.

  • As implemented RHNA (1) incentivizes excessive opportunistic and undisclosed Market Rate development, (2) especially in high-value areas ("well-resourced"), which (3) creates high risk to community finances and environmental resources, (4) without materially impacting the affordability objectives that have been used as its justification.

    • The California State Auditor's evaluation of the Department of Housing and Community Development's RHNA process reveals inadequacies, emphasizing that "HCD does not ensure that its needs assessments are accurate and adequately supported."

    • San Francisco's inflated RHNA lacks consideration for economic and post-pandemic factors, raising concerns about transparency and the potential misuse of the "Builder's Remedy" without achieving public input.  An audit is urged to scrutinize the RHNA goal and assess the city's infrastructure readiness for such extensive and ineffectual transformation.

    • VIDEO: The Housing Supply Crisis: The State's False Narrative that Supports Investor Profits.

      • RHNA appears to be only tangentially relevant to the affordability problem being used as its justification​

      • RHNA process lacks a standardized framework, which enables opportunistic manipulation in the mandate-setting process

      • RHNA mandates are based on a concept of "need" that is neither demographic nor economic, allowing significant discretion

      • Projected Need: Household projections based on interpretations of state population projections with a heavy historical (growth) bias​

      • Existing Need: Estimated accrued housing shortage in the current population based on an ad hoc combination of vacancy rates, overcrowding, and cost-burdening

      • RHNA's Affordable Housing mandates are unfunded despite being the core justification for RHNA; require "inclusionary" development

      • Inclusionary strategy results in overwhelming (and undisclosed) market rate construction: RHNA is a market rate machine

      • RHNA is economically untethered: Assumes construction continues in declining price environments

      • Process has been captured by special interests and is inaccessible to the public ... by design

  • Who decided the RHNA numbers?  Article: The State Housing secrecy just keeps getting worse and worse: crucial planning decisions are made behind closed doors, with Yimby stakeholders—and the public can't even get the basic records.

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