Abundant Housing LA (AHLA) is pleased to see that the California State Auditor has identified ways to improve the Regional Housing Needs Assessment (RHNA) process. We are also encouraged that the California Departments of Housing and Community Development (HCD) and Finance (DOF) have committed to implementing the audit’s recommendations for their agencies. The audit underscores the need for adequate review procedures, improved staffing, and clearer guidance from the state.

The audit considered three housing needs assessments for the Santa Barbara County Association of Governments, Sacramento Area Council of Governments and Amador County, and thus did not include the Southern California Association of Governments (SCAG) region where AHLA has been conducting housing element reviews. AHLA remains committed to ensuring that local governments in Los Angeles County fulfill their moral and legal obligations to plan for an adequate supply of homes at all income levels, remove governmental constraints to housing production and affirmatively further fair housing.

The errors identified in the audit include human errors when entering data, as well as technical inadequacies. Specifically, the state auditor found inadequate analysis of vacancy rates that was used to make adjustments to assessed needs, problematic projections of household growth, improper methods for considering jobs/housing imbalance, and failure to account for housing lost to emergencies. Many of these errors resulted in housing needs assessments projecting less need than was appropriate. None resulted in the “double counting” of overcrowding and cost-burdening. 

AHLA engaged early in SCAG’s RHNA process and advocated for a higher overall RHNA than was ultimately adopted to completely eliminate cost-burden and overcrowding for the region’s households. While the current cycle’s RHNA is a more accurate reflection of true housing need than in past cycles and does take into account cost-burden and overcrowding, the audit points to the need for broader reforms in the RHNA process to raise ambition and set more objective standards for housing element adequacy in future cycles. We look forward to working with HCD and SCAG on ensuring a more accurate 7th cycle RHNA that truly captures the full housing need of the region.


Leonora Camner

Executive Director

Abundant Housing LA

David J. Barboza, AICP

Director of Policy and Research

Abundant Housing LA


Abundant Housing LA is a pro-housing, nonprofit advocacy organization working to help solve Southern California’s housing crisis. We support reforms to legalize more homes, make homes easier to build, increase funding for affordable housing, and protect tenants, which are all needed to make housing more affordable, improve access to jobs and transit, promote greater environmental sustainability, and advance racial and economic equity. As a community organization, in order to maintain our independence, we do not accept financial support from housing developers or their consultants.


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