Using the Housing Element of the General Plan to build resilience

About the Housing Element 

In California, the Housing Element is a required component of a local government’s General Plan. Like the General Plan itself, the Housing Element is a blueprint for how a city or county plans to meet current and projected housing needs. Read more about Creating a General Plan.

As prescribed in California law since 1969, local governments are required to adopt plans and zoning regulations that allow for and do not constrain future housing needs. State law requires localities to use their local land use authority to zone more than enough land zoned to accommodate projected housing needs. However, the law does not require local governments to ensure sufficient housing is actually developed.

The Department of Housing and Community Development (HCD) has several resources that describe the Housing Element process.  

How it works 

State law requires local jurisdictions to update their Housing Elements every eight years. A vital component of the Housing Element update process is the Regional Housing Needs Assessment (RHNA).  

1. HCD determines the total amount of new housing that needs to be produced for each region and assigns these totals to regional planning agencies (either Metropolitan Planning Organizations (MPO) or Councils of Government (COG)). For example, the Association of Bay Area Governments (ABAG) completes this process for the nine-county Bay Area. This number is referred to as a region’s Regional Housing Needs Determination. 
2. That MPO/COG allocates their Regional Housing Needs Determination across all the local jurisdictions in their region, according to a RHNA methodology the MPO/COG designs, with approval from HCD. This number is referred to as a city or county’s Regional Housing Needs Allocation. 
3. Each local jurisdiction updates their Housing Element based on their Regional Housing Needs Allocation from the RHNA cycle. 
4. Local jurisdictions send their updated Housing Element to the California Department of Housing and Community Development for approval.  
5. Local jurisdictions adopt the Housing Element as part of their General Plans.  

Structure of a Housing Element 

There are five key components to the Housing Element update process: 

1. Review previous Housing Element and progress  
2. Identify housing needs 
3. Identify government and non-governmental constraints  
4. Sites inventory and analysis 
5. Goals, programs, and policies 

Use this checklist to make ensure compliance with all the requirements. 

Impact on frontline communities  

Despite the goals of RHNA and Housing Elements, in practice, challenges persist in meeting the outcomes of equitable development across regions and localities. Historically, the RHNA process has allowed more affluent jurisdictions to lobby to keep their allocation numbers artificially low. An analysis of historical allocations in the Bay Area found that cities with a higher white population were more likely to receive lower housing target goals for moderate- and lower-income housing. 

Once these allocations are determined, however, still far too many jurisdictions consistently fail to meet their housing production targets, especially for housing that is affordable to low- and moderate-income households. 

In recent years, State lawmakers have tried to reform the Housing Element Law and RHNA to be more effective and equitable, but it will take years to see and evaluate the impacts of these changes. These memos from HCD describe these recent changes in the laws that govern Housing Elements. 

Actions to take 

The housing shortage in California is severe and exacerbated by California’s increasingly destructive wildfires. California’s regions and local governments have an unprecedented challenge: to plan for and support future development patterns with more housing, less sprawl, and reduced vulnerability to disasters. The Housing Element is a local government’s most foundational document focused on housing needs. Frontline communities deeply understand the needs and risks in their communities and should be actively involved in the creation of the RHNA methodology and Housing Element. 

For community-based organizations and affordable housing providers 

• Follow along with your local MPO or COG to find out when the RHNA process will happen. Participate in the process as much as possible.  
• Follow along with your local Planning Office to find out when they are working on the next Housing Element. Work with the local jurisdiction to help them fully understand housing insecurity and precariousness.  
• The City of Anaheim has creative, fun videos that explain the RHNA and Housing Element process in detail.

For local government 

• Represent housing insecurity and precariousness as fully as possible. The Housing Element Law requires localities to provide special consideration for addressing housing needs for seniors, single-parent households, farmworkers, and people experiencing homelessness. However, many precarious housing situations do not neatly fit into these boxes. Explore ways to estimate the number of residents facing additional types of precarity (examples below). Interviews with community-based organizations and housing advocates can help you effectively audit precarious housing situations. By taking steps to fully represent housing insecurity and precariousness in a community, local jurisdictions are setting the stage for more appropriate post-disaster planning and funding, which is in part determined by a jurisdiction’s pre-identified needs.  
  • Example: Housing insecurity is not counted as homelessness, although these individuals are the most likely to experience homelessness after a disaster. One way to estimate this insecurity is by measuring how many people are rent-burdened. 
  • Example: People living in homes passed down between generations and do not have formal title to the property, especially common in rural communities.  
  • Example: Residents living in substandard housing, which makes households more vulnerable to disaster and post-disaster displacement.  
• Incorporate resilience policies throughout the Housing Element. The Association of Bay Area Governments has great examples in this resource. 

For philanthropy 

• Housing Element updates are important moments of influence for community-based organizations to shape their jurisdictions’ housing policies.  
  • Philanthropy should fill the local planning gap and support community-based organizations to develop resident-centered plans to influence the Housing Element during planning updates. Work with HCD or the local MPO/COG to determine who might need support with completing their Housing Elements.