Report 2021-125 Recommendation 3 Responses

Report 2021-125: Regional Housing Needs Assessments: The Department of Housing and Community Development Must Improve Its Processes to Ensure That Communities Can Adequately Plan for Housing (Release Date: March 2022)

Recommendation #3 To: Housing and Community Development, Department of

To demonstrate that its needs assessments are complete and address all relevant factors, by September 2022 HCD should establish a formal process to document its consideration of all factors required by state law in its needs assessments.

6-Month Agency Response

HCD has established a formal process for documenting its consideration of all factors required by state law in its needs assessment, which will be implemented in a transparent and uniform manner. To document its process, HCD has added explanatory notes describing how every factor required by state law is considered in the Regional Housing Need Determination letter template that is transmitted to the regional councils of government. HCD also incorporated steps into the checklist developed in response to recommendation #1 that prompts HCD to confirm whether the COG has submitted data related to the jobs housing imbalance and state of emergency adjustment factors. This documentation is intended to implement the actions HCD committed to in its March 4, 2022 response to the Auditor's report.

HCD is also planning to go above and beyond the changes the Auditor requested in the 2021-125 Audit. In the coming months, HCD is planning to convene a public process to discuss and identify alternate jobs-housing imbalance data sources, methodologies, and recommended targets. This process will include the convening of a panel of experts with relevant expertise in the field of jobs-housing imbalance, planning, and/or best practices, all as determined, identified, and selected by HCD.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

60-Day Agency Response

HCD will establish a formal process for documenting its consideration of all factors required by state law in its needs assessment.

HCD will convene a public process to discuss and identify jobs-housing balance data sources, methodology, and recommended targets. This process shall include a panel of experts with relevant expertise in the field of jobs-housing imbalance, planning, and/or best practices, all as determined, identified, and selected by HCD.

To the extent HCD adopts a jobs-housing balance methodology and recommended targets, HCD will apply such targets or methodology to future determinations. HCD shall use reasonable and good faith efforts to ensure that any methodologies deployed are transparent and uniformly applied.

If and to the extent necessary and appropriate data is available and reliable, as determined by HCD, HCD will make written determinations on whether each region has a current and/or projected imbalance between jobs and housing.

If not provided, HCD will request employment projections from the COG to consider using in any jobs/housing adjustment factor.

If not provided, HCD will request that data from the COG related to units lost during a state of emergency be submitted to HCD. HCD will work with Department of Finance and other agencies to verify data submitted by the COG contains a complete accounting of all units lost during the state of emergency and will incorporate the adjustment factor into all determinations in a transparent and equitable manner.

To the extent HCD adopts a jobs-housing balance data source, methodology, and recommended targets, HCD will formally incorporate such jobs/housing methodology and recommended targets, along with explanatory notes regarding the same into the Regional Housing Need Determination letter template to be transmitted to the regional councils of government.

California State Auditor's Assessment of 60-Day Status: Pending

All Recommendations in 2021-125

Agency responses received are posted verbatim.