The California State Auditor is conducting an audit of the state’s housing element review process.
The audit, according to California State Auditor Grant Parks, will provide independently developed and verified information related to the California Department of Housing and Community Development’s procedures and oversight regarding housing element reviews.
The audit’s scope will include, but not be limited to, the following activities pertaining to HCD and 10 cities selected by the State Auditor for their diversity in population, geography, and compliance with HCD’s housing element standards:
1) Review and evaluate the laws, rules, and regulations significant to the audit objectives.
2) Identify and evaluate HCD’s requirements and guidance for local housing elements. Perform the following:
- Determine whether HCD’s standards and guidance are detailed enough for cities to apply to their housing elements.
- Assess whether HCD is available for assistance when cities are developing their initial drafts of housing elements and determine the median time cities wait for assistance from HCD.
3) Assess HCD’s responsiveness in reviewing housing elements for the 10 selected cities by doing the following:
- Identify the median range of time HCD took to complete each review (or reviews) of the fifth and sixth housing element cycles.
- Identify the median range of time HCD took to approve the housing elements and compare these times to the times of those from the fifth housing element cycle.
- Assess how and when HCD communicated housing element submission deadlines for the sixth housing element cycle. Determine whether these deadlines differed from the fifth housing element cycle.
4) Evaluate HCD’s comments and feedback to each of the 10 selected cities in the sixth housing element cycle by doing the following:
- Determine the consistency of HCD’s comments among the 10 selected cities.
- Determine whether HCD reviewers provided precise, measurable, and criteria-based comments and feedback.
- Compare the overall comments and feedback to HCD’s comments and feedback on the Affirmatively Furthering Fair Housing standards and site analysis requirements of the housing element.
5) Evaluate HCD’s staffing levels and turnover rate, to the extent data is available, by doing the following:
- Identify the total number of reviewers HCD had in the fifth and sixth cycles. For each cycle, determine the median time that reviewers worked at HCD. Compare the turnover and totals between the two cycles.
- Determine the median number and full range of reviewers that evaluated the housing elements of each of the 10 selected cities.
- Determine how long a reviewer remained assigned to the same local government in the sixth housing element cycle and compare this time to the average for the fifth housing cycle.
6) Identify and evaluate HCD’s policies and procedures for training new and existing staff assigned to review housing elements and determine the following:
- The length of time for and procedures taught in new employee training.
- Whether HCD offers additional training to existing staff and, if so, how often and on what topics.
- Whether HCD’s training is sufficient to prepare reviewers to review housing elements and provide clear comments to local governments.
7) Review and assess any other issues that are significant to the audit.
The California State Association of Counties is encouraging counties to provide comments and feedback to the auditor’s office with their experiences with the state’s housing element review process.
This audit request was put forth by Sen. Steve Glazer (D-Orinda) and received unanimous approval from the Joint Legislative Audit Committee.
CSAC supports this audit based on feedback from counties about the challenges they faced in the 6th Regional Housing Needs Allocation cycle and achieving housing element certification from the Department of Housing and Community Development.
The audit provides an opportunity to highlight ways to improve the housing element review process in the future.
Counties can submit comments and feedback about their individual experiences with HCD during the last RHNA cycle to the auditor’s office.
These comments will help the state auditor’s office better understand the complexity of the housing element review process and how more technical assistance, financial resources, and other solutions could help cities plan more effectively for much-needed housing.
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Counties can participate in the audit by submitting comments about their experiences with the 6th RHNA Cycle to audit-2024-109@auditor.ca.gov.