Equity Adjustment Contributes to Piedmont Tenfold Increased Housing Allotment
Piedmont’s Regional Housing Needs Assessment (RHNA)
Jumps from 60 to 587 housing units in the next
Planning Cycle that begins in 2023
An “equity adjustment” formula was proposed that increases the allocations of lower-income units for some jurisdictions identified as having racial and socioeconomic demographics that differ from the regional average. Five jurisdictions that met the formula were excluded. These jurisdictions were excluded from the equity adjustment to avoid directing additional lower-income RHNA units to jurisdictions with racial demographics that are different than the rest of the region but that already have a high share of lower-income households.
[See the equity adjustment tables which begin on page 31 of this report.}
The equity adjustment identified 49 jurisdictions in the Bay Area that exhibit racial and socioeconomic demographics that differ from the regional average using a composite score developed by several members of the Housing Methodology Committee (HMC). The purpose of the equity adjustment is to ensure that each of these 49 jurisdictions receives an allocation of lower-income units that is at least proportional to its share of the region’s total households in 2020.
For example, if a jurisdiction had two percent of existing households, it would receive at least two percent of the very low- and low-income RHNA units. The composite score is calculated by adding together the jurisdiction’s divergence index score (which measures segregation by looking at how much local racial demographics differ from the region) and the percent of the jurisdiction’s households with household incomes above 120 percent of the area median income (AMI).
Jurisdictions with a composite score greater than the median score for the region are included in the group of “exclusionary” jurisdictions. Accordingly, a jurisdiction does not necessarily need to have an extremely high divergence score or percent of households above 120 percent AMI to be considered “exclusionary,” as a jurisdiction’s composite score only needed to be in the top half for all Bay Area jurisdictions.
The equity adjustment excludes five jurisdictions who have composite scores above the region’s median, but median incomes in the bottom quartile for the region. These jurisdictions were excluded from the equity adjustment to avoid directing additional lower-income RHNA units to jurisdictions with racial demographics that are different than the rest of the region but that already have a high share of lower-income households.
The equity adjustment is the last step in the allocation methodology, and is applied after the methodology’s factors and weights are used to determine a jurisdiction’s allocation by income category. If the allocation of lower-income RHNA units to one of the 49 jurisdictions identified by the equity adjustment’s composite score does not meet the equity adjustments proportionality threshold, then lower-income units are redistributed from the remaining 60 jurisdictions.
Understanding the formula by reading the long tables is challenging. Piedmont residential locations were rated virtually identical (18, 19) in terms of very low income job proximity via auto (18) and very low income job proximity via public transit (19), and low income job proximity via auto (10) and low income job proximity via public transit (11) despite the fact that most of Piedmont is more than a quarter mile pedestrian path walk from public transit with service for work schedules.
In comparison, Pinole scored 13, 13 low income job proximity via auto, transit. Portola Valley scored 7, 5 very low income job proximity via auto, transit, and 4, 3 low income job proximity via auto, transit. Ross scored 2, 3 very low income job proximity via auto, transit and 1, 2 low income job proximity via auto, transit. Tiburon scored 14, 15 very low income job proximity via auto, transit and 8,8 low income job proximity via auto, transit. After adding other factors, low density Tiburon with a land area of 4.4 square miles for a population nearly as large as Piedmont, was assigned an RHNA of 639, slightly more than Piedmont.
Often lost in the local enthusiasm is the fact that the planning cycle is 2023 through 2031 and the State law explicitly does not require local jurisdictions to produce or pay for the new housing units it is asked to plan for.
