Press Release: State Audit Confirms Flaws in CA's Housing Needs Assessments. Housing Goals Deemed Too Low in Many Cities.

Contact: Jae Garner

On Thursday March 17, 2022, the CA State Auditor’s Office (CSA) released their audit of the Regional Housing Needs Assessments (RHNA) process and outlined serious deficiencies in the state’s housing needs assessment process. According to the report, the CA Department of Housing and Community Development (HCD) “does not ensure that its needs assessments are accurate and adequately supported.” This has resulted in an underestimate of housing needs in multiple regions. 

The audit included recommendations for HCD to assess the balance between the number of jobs compared to homes in each region, or the “jobs housing balance,” highlighting an issue brought by YIMBY Law and YIMBY Action in a suit filed in February of last year (“YIMBYs Sue for Even More Housing Via RHNA”). 

“This confirms YIMBY Law's belief that our state housing goals - while daunting to cities that have systematically blocked housing for decades - in fact underestimate the critical need for more homes in our state. Significant progress has been made in our housing needs assessment process, and our housing goals are more ambitious than ever before. Still, YIMBY Law has pointed to flaws in the state’s housing needs assessment process and is pleased that these issues underestimating the need for housing are finally seeing the light of day,” said Rafa Sonnenfeld, Director of Legal Advocacy at YIMBY Law.  “I cannot overstate the importance of HCD’s process being both accurate and trustworthy for meeting the housing needs of all Californians.”

“Setting - and meeting - state housing goals that address the true needs of our state is the only way we can build a future for people from all kinds of backgrounds and all walks of life. If we want to live up to our inclusive values and build a California that can thrive, we must ensure that all Californians have a place to live,” said Laura Foote, Executive Director of YIMBY Action. “In light of this audit, it is more important than ever to recognize that our Regional Housing Needs Allocations are a floor, not a ceiling, for housing production. RHNA goals underestimate the true need for more homes in our communities. Cites can and should build even more homes.”

These results are likely unexpected for critics of HCD, who originally called for an audit in the hopes that regional housing goals had been set too high. Led by Senator Steve Glazer, many legislators who called for this audit represent some of California’s lower density districts who have continued to oppose the RHNA process. Many cities in these districts appealed the number of homes assigned to them in the recent Regional Housing Needs Allocation process, asserting that the numbers assigned to them were too high. Some skeptics of the RHNA process asserted that an accurate allocation would result in their assigned number of homes being cut in half. In the Bay Area alone, 27 jurisdictions challenged their allocations. All but one of these appeals was denied.

Across multiple jurisdictions, errors in housing allocation determinations resulted in lower numbers of housing production goals. In all examined regions, the audit found that HCD failed to include the jobs housing balance. The jobs housing balance is an essential part of evaluating economic opportunity as it relates to the availability of homes in communities across the state. Without an accurate assessment of this relationship, workers will be forced to live further from their jobs. This will lead to increased car usage, carbon emissions, and wealth inequality. The CSA, HCD, and YIMBY Law agree: the jobs housing balance must be added as a specific adjustment factor in this process.

Auditors pointed out several changes needed to increase the accuracy of the needs assessment and ultimately increase the number of homes assigned to cities across California. With a housing shortage of over 3.5 million homes and decades of underdevelopment, the housing needs determination process is necessary to allow jurisdictions to plan for the homes Californians need. YIMBY Law urges HCD to implement the recommended improvements immediately.