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hearings were held for the 2007 Integrated Growth Forecast/RHNA methodology. The RHNA <br />methodology did not result in a favorable outcome for many cities, especially for those cities that <br />were not able to calculate the housing vacancy rate as part of meeting the housing need. Colton <br />was assigned the responsibility to provide housing programs that would result in the construction <br />of 3,106 dwelling units by the year 2014. <br />On February 1, 2007, SCAG presented a report on the status of RHNA Pilot Program (Senate <br />Bill 12) and Amended Appeals Procedure to address a revision process required under SB12. It <br />is through this process that the City of Colton is formally appealing the R1 NA figures for 2006 <br />to 2014 of 3,106 dwelling units. <br />DISCUSSION/ANALYSIS: <br />Using the guidelines outlined in the RHNA appeal process for forecasting future housing, the City <br />of Colton is petitioning the housing number of 3,016 for the period of 2006 to 2014. The City of <br />Colton is not opposed to all aspects of the proposed pilot program in SB 12. However, the City of <br />Colton appeals the RHNA housing numbers based on Methodology and AB 2158 Factors. <br />Our appeal would be based on the following arguments: <br />1. The RHNA numbers assigned to the City would require housing starts of approximately <br />345 units per year. The City issued 317 housing permits between the years of 2002- <br />2006, and average of 63.4 per year. <br />2. The RHNA allocation to Colton does not take into account the amount of land <br />constrained by the Delhi Sands Flower Loving Fly. Thus, even though such land is <br />vacant and may be zoned for housing development, it is not truly available within the <br />planning period. <br />3. The RHNA numbers assigned to Colton do not take into account the City's high <br />vacancy rates — meaning that there is really more housing available than Colton is given <br />credit for. <br />Staff is researching additional arguments with other surrounding cities. Letters appealing the <br />RHNA numbers are due on March 15, 2007. <br />FINANCIAL IMPACT: <br />There is no impact to the General Fund. <br />ENVIRONMENTAL IMPACT: <br />None. <br />CONFLICT OF INTEREST: <br />None. <br />RECOMMENDATION: <br />Authorize staff to submit a letter to SCAG under the Mayor's signature, appealing the RHNA <br />numbers for housing units to be constructed in the City of Colton. Staff is working with the City <br />Attorney and other cities to formalize additional arguments. <br />