The Marin Post

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State Audit of HCD finds insufficiency

The State Audit Department completed its investigation of the Department of Housing and Community Development (HCD) re: Regional Housing Needs Assessments (RHNA).

Why does this matter? The nine counties and 101 cities of the Bay Area are staggering under the weight of RHNA mandates for the 8-year cycle (2023-2031). For example, Mill Valley is required to produce 865 NEW units of housing, disregarding fire and flood hazards, congestion, overcrowding with lack of parking, or finding a source of water. Other cities face equally unrealistic and dangerous numbers. The housing quotas are supposedly going to meet the need for housing that is "affordable," but growing evidence shows that premise is unfounded. Density increases housing and living expenses.

The highlighted conclusion in the Fact Sheet (3/17/22) says, "HCD must improve its processes to ensure that communities can adequately plan for housing."

Key findings include:

  1. HCD has not sufficiently reviewed and supported housing needs assessments.
  2. Although Finance provides reasonable population projections, it has not provided sufficient support for its projections of the number of households that are likely to be formed in the future.

The Audit recommends HCD should do the following:

  1. Institute a process to ensure that its staff performs multiple reviews of data in its assessments and establish a formal process to document its considerations of all factors required by state law in needs assessments.
  2. Perform a formal analysis of healthy housing vacancy rates and historical trends to inform its adjustments in this area.
  3. Develop a formal process to review the appropriateness of data that consortia of local governments submit.

It also recommends that Finance should conduct and document a comprehensive review of some of its assumptions about household formation rates it uses in projections.

YIMBYs are claiming the report will substantiate their claims that HCD under-counted the state housing needs.

On the other hand, however, this report discredits HCD and may provide a pathway to relief from the inflated and unattainable RHNA numbers cities and counties are under the gun to comply with. The findings are aligned with the 2020 report done by the Embarcadero Institute entitled, "Double counting in the latest housing needs assessment."

If you enjoy taking deep dives into the weeds, please join us in looking at the details of this report.


HCD, RHNA, Audit, Embarcadero Institute