City of Coronado v. San Diego Assn. of Governments

I.

INTRODUCTION

“The Legislature enacted the regional housing needs assessment (RHNA) procedure . . . to address the state’s shortage of affordable housing.” (San Franciscans for Livable Neighborhoods v. City and County of San Francisco (2018) 26 Cal.App.5th 596, 610.) As a component of this process, “[v]arious regional councils of governments, in conjunction with the cities and counties within their jurisdictions and the California Department of Housing and Community Development (HCD), devise methods for distributing existing and projected housing needs within their regions and for allocating a share of the regional housing needs to each local jurisdiction.” (Ibid.) In City of Irvine v. Southern California Assn. of Governments (2009) 175 Cal.App.4th 506 (City of Irvine), the Court of Appeal concluded that “the administrative procedure established under Government Code section 65584[ 1] et seq. . . . to calculate a local government’s allocation of the regional housing needs assessment (RHNA) is intended to be the exclusive remedy for the municipality to challenge that determination and thereby preclude[s] judicial review of the decision.” (Id. at p. 510.) Among other reasons…