Regional Housing Needs Assessment (RHNA)

RHNA Overview

Since 1969, cities and counties in California have been required to plan for future housing needs for all income levels by including a Housing Element in their General Plan. State housing officials have stated that in order to adequately address the housing needs and demand of Californians, local governments must adopt plans and regulations that provide opportunities for (and do not unduly constrain) the private market to develop housing. Every 8 years, housing needs are assessed within the different regions of California. After identifying regional housing needs, the total number of housing units projected to be needed for each income level is distributed among the jurisdictions in the region. This is called the Regional Housing Needs Allocation or “RHNA” (pronounced “reena”). Jurisdictions must then update their Housing Elements to identify policies and specific locations for residential development to provide the opportunity to reach the jurisdiction’s RHNA allocation.

The Bay Area region’s 2023-2032 RHNA process started in October 2019. The draft housing allocation for Saratoga and other jurisdictions is expected by spring 2021 with the final allocation being provided by winter 2021. Jurisdictions will then use their individual RHNA allocation to submit a draft updated Housing Element to HCD in 2022 and to adopt by January 2023.

As background, the following table shows Saratoga’s RHNA allocation for 2015-2023 for each income category together with the number of building permits that the City has issued in each category as of December 31, 2019.  The City has not denied any applications for new residential development in the planning period.

Income CategoryUnits AllocatedPermits Issued
Extremely Low & Very Low Income (0-50% Area Median Income)

Low Income (51-80% Area Median Income)
63 (ADUs)
Moderate Income (81-120% Area Median Income)
16 (ADUs)
Above Moderate Income (120%+ Area Median Income)
27 (new homes)
* ADU - Accessory Dwelling Units
* The number of permits shown above reflects building permits issued authorizing construction, not approval of planning applications.

Housing Needs Allocation for the Bay Area

Based on growth projections from the State Department of Finance, the California Department of Housing and Community Development (HCD), in partnership with a Council of Governments for each region, determines housing needs within each of the 18 regions in the State. Each Council of Government for the different regions is then responsible for divvying up the housing needs among all the jurisdictions within that region. The Council of Government that represents the counties of Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, Santa Clara, Solano, and Sonoma is the Association of Bay Area Governments (ABAG).

In June 2020, HCD provided the housing needs allocation for the Bay Area for the 2023-2032 period. The total number of new housing units needed is 441,176. This compares to 187,990 for the prior planning period of 2015-2023 representing a 234% increase in future housing to be planned for in the Bay Area

Allocation of Housing Needs to Bay Area Jurisdictions

The next step in the RHNA allocation process is for the Association of Bay Area Governments (ABAG) to determine individual allocations for each jurisdiction (cities and counties).

The ABAG Executive Board, based on recommendations from ABAG’s Housing Methodology Committee, will adopt a methodology for distributing the total housing needs to each of the jurisdictions in ABAG’s territory. The ABAG Executive Board is comprised of elected officials from throughout the Bay Area who are selected to serve on the Board by fellow elected officials in the different counties. In Santa Clara County, the city representative on the ABAG Executive Board is selected by the Cities Association of Santa Clara County. The Housing Methodology Committee includes 9 elected officials from each of the Bay Area counties, 12 housing or planning staff, 16 stakeholders representing a variety of perspectives, and 1 partner from the State. A Committee roster is available on the ABAG website.

ABAG is required to follow several objectives from the State when deciding each jurisdiction’s share of the total Bay Area housing needs allocation. These include:

  1. Increasing housing supply and mix of housing types, tenure, and affordability in all jurisdictions in a fair manner
  2. Promoting infill development and socioeconomic equity, as well as protection of environmental and agricultural resources, encouragement of efficient development, and supporting the State’s greenhouse gas emission reduction targets
  3. Promoting the relationship between jobs and housing, including improving the balance between the number of low-wage jobs and the number of affordable housing units in each jurisdiction
  4. Reducing the number of units needed in an income category when a jurisdiction has an already high share of households in that income category
  5. Furthering fair housing by reducing patterns of segregation, addressing disparities in housing needs and access to opportunity, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws

Allocation Methodology

The Housing Methodology Committee finalized its recommended allocation methodology on September 18, 2020. The allocation methodology received support from the ABAG Regional Planning Committee on October 1 and was considered by the ABAG Executive Board during its meetings on October 15 (Meeting Agenda and Video) and December 17 (Meeting Agenda and Video). Additionally, informational materials on the allocation methodology presented to the ABAG Executive Board at the October 15 meeting are below. 

The allocation methodology is based on several guiding principles. 

  1. Increase housing where there are more jobs than housing
  2. Increase housing in areas where wealth is concentrated and where there is a lack of racial diversity
  3. Focus on creating housing opportunities in High Opportunity Areas

Based on these principles, a formula was developed for allocating the 441,176 new housing units to the Bay Area by HCD to all the jurisdictions in the Bay Area. The table below shows the estimated RHNA allocation for the City of Saratoga (ABAG Regional Planning Committee Allocation Methodology Informational Materials - Appendix 2). The final draft RHNA allocation for Saratoga will be provided by Spring 2021.


Very Low IncomeLow IncomeModerate IncomeAbove Moderate

About Income Levels:

  • Very Low Income < 50% of the Area Median Income (AMI)
  • Low Income 50% – 80% of AMI
  • Moderate Income 80% - 120% AMI
  • Above Moderate Income > 120% AMI

The Area Median Income is determined annually for each county by HCD.  The 2020 AMI for Santa Clara County is $141,600 for a four-person household.

City of Saratoga Input on Methodology

Draft RHNA Methodology & Plan Bay Area 2050 Webinars

ABAG hosted webinars on December 18 and January 5 for the public to learn more about the analysis outcomes in the Final Blueprint for Plan Bay Area 2050 strategies, and the Draft RHNA methodology. View the recording of the December 18 webinar.

The public can also sign up for the RHNA mailing list to receive updates via email.

Housing Element

Once the RHNA allocation to all the Bay Area cities and counties are finalized by the ABAG Executive Board, each jurisdiction will begin updating its Housing Element. The Housing Element is one of several General Plan Elements that cities and counties in California are required to have. The General Plan is a long-term policy document that provides guidance for managing physical, social, and economic resources. The Housing Element describes how a jurisdiction will address housing needs.

The Housing Element includes 7 components:

  • Housing Needs Assessment that provides demographic and housing need information for the City.
  • Constraints Analysis of existing and potential constraints on housing development and how those will be addressed.
  • Evaluation of Past Performance that assesses the City’s progress in implementing the policies and programs in the previous Housing Element
  • Housing Sites Inventory and Analysis that identifies sites available for development or redevelopment and that are appropriately zoned to support housing development
  • Housing Resources that identifies financial and other resources available to support housing development
  • Policies and Programs that are designed to address housing needs in the City.
  • Community Outreach efforts conducted as part of the Housing Element update.

The City of Saratoga’s current Housing Element became effective in 2015 and must be updated by 2023. Development of the 2024-2032 Housing Element will begin in Fall 2021. Following public review and consideration by the Planning Commission and City Council the City must submit a draft of the Housing Element to HCD for its review.  The City must adopt the final Housing Element and submit it to HCD by January 2023.

The Housing Sites Inventory is a key part of the Housing Element.  The inventory must show the specific sites in the City that have zoning adequate to ensure that the number and types of units in the City’s allocation can be built. Recent changes in State law require more detail on these sites than was required for the past Housing Element. Specifically, new state laws require that the siting inventory include:

  • Adequacy of infrastructure to support the site;
  • Adequacy of the site size to accommodate housing for lower-income households as such projects typically require 50-150 units.
  • The RHNA income category the site is expected to serve (if the site is later developed for a different income category the City must then identify a new site or sites for a similar amount of the targeted development type);
  • A discussion of whether the site was included in previous inventories and, if so, why it has not yet been developed;
  • A description of how the sites affirmatively further fair housing (defined as taking meaningful actions that, collectively, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws.
  • For sites that are not vacant, an explanation of why it is reasonable to expect that the site will be redeveloped with housing before 2032. 

State Housing Legislation

In recent years, the State has adopted a number of housing laws that shift more responsibility for development of affordable housing from the market to local jurisdictions and reduce local control over future residential development. The most significant in Saratoga area:

  • Senate Bill 35 (Weiner): requires cities and counties where housing production has not matched the Housing Element targets to use a streamlined, ministerial review process (e.g., not allowing environmental review or any discretionary findings such those used for design review and similar approvals in Saratoga) for qualifying multifamily residential projects.
  • SB 330 (Skinner): prohibits agencies from holding more than five hearings/public meetings concerning residential projects and prohibits adoption zoning or General Plan policies that lessen the intensity of housing.
  • Senate Bill 166 (Skinner): prohibits cities from requiring that sites identified in the Housing Element for affordable housing be developed as affordable housing and requires cities to identify new locations for affordable housing if the affordable housing sites are developed for another use or market-rate housing.

Public Input on Legislation

The community can subscribe to receive automatic email updates on proposed bills on the California State Legislature website. The public can also share their thoughts on a proposed bill with their State representatives or submit a position letter to the Committee considering the bill using the State’s Position Letter Portal.