Report 2021-114 All Recommendation Responses

Report 2021-114: State Surplus Property: The State Should Use Its Available Property More Effectively to Help Alleviate the Affordable Housing Crisis (Release Date: March 2022)

Recommendation for Legislative Action

To ensure that the creation of affordable housing made available under the excess state property executive order continues, the Legislature should enact state laws to require that DGS and HCD carry out the duties prescribed in Executive Order N-06-19. Further, the Legislature should require the following:

- By September 2022, DGS should develop a set of criteria to consistently evaluate state parcels for suitability as affordable housing sites.

- By July 2023 and every four years thereafter, DGS should conduct a review of all state-owned property and identify parcels that are potentially viable for affordable housing based on the established criteria. Once this review is complete, follow up with all related agencies to determine property availability. After the completion of each review, DGS and HCD should prioritize the identified properties for development.

Description of Legislative Action

AB 2233 (Chapter 438, Statutes of 2022) requires DGS to develop, in consultation with HCD and no later than September 1, 2023, a set of criteria to consistently evaluate state-owned parcels for suitability as affordable housing sites. The bill also requires, on or before July 1, 2024, and every four years thereafter, DGS to, among other things, conduct a review of all state-owned property and identify state-owned parcels that are potentially viable for affordable housing based on those criteria. This bill requires DGS to contact all related agencies following each review to determine excess state land. On or before January 1, 2024, and annually thereafter, this bill requires DGS to report to the Legislature on the status of excess state properties.

This bill requires the DGS to update, on or before January 1, 2024, a digitized inventory of all excess state land. The bill requires DGS, and HCD no later than June 1, 2023 and annually thereafter, to evaluate and update the screening tools jointly developed pursuant to Executive Order N-06-19. This bill requires all state agencies to respond to requests for information from the DGS, as described, and to consider exchanging excess state land with local governments for other parcels for purposes of affordable housing development and preservation. The bill also requires all state agencies to use all existing legal and financial authority, subject to the direction of the Governor, to expedite and prioritize developments accepted pursuant to the request for proposal process described in the bill.

California State Auditor's Assessment of 6-Month Status: Legislation Enacted

Description of Legislative Action

AB 2233 (Quirk-Silva and C. Garcia, February 2022) would require DGS to develop, no later than September 1, 2023, a set of criteria to consistently evaluate state-owned parcels for suitability as affordable housing sites. The bill would require that DGS, on or before July 1, 2024, and every 4 years thereafter conduct a review of all state-owned property and identify state-owned parcels that are potentially viable for affordable housing based on those criteria. The bill would require DGS to issue a report on the results of each of its reviews.

Consistent with the duties prescribed in Executive Order N-06-19, the bill would require DGS to create, no later than April 30, 2024, a digitized inventory of all excess state land by conducting a comprehensive survey of all state-owned property. The bill would require DGS, HCD, and the California Housing Finance Agency to develop, no later than March 29, 2024, two new screening tools, to apply the screening tools to the digitized inventory, and for DGS to create a comprehensive map of excess state land. The bill would require all state agencies to respond to requests for information from DGS and to consider exchanging excess state land with local governments for other parcels for purposes of affordable housing development and preservation. The bill would require all state agencies to use all existing legal and financial authority to expedite and prioritize developments accepted pursuant to the RFP process, as described. The bill would require DGS, in consultation with HCD, to issue requests for proposals on individual state-owned parcels and accept proposals from developers of affordable housing interested in entering into low-cost, long-term ground leases of parcels on the comprehensive map. The bill would require the selection process for the proposals to be implemented no later than September 30, 2024. As of June 10, 2022, this bill is pending in the Senate.

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

As of June 10, 2022, AB 2233 (Quirk-Silva and C. Garcia, February 2022) is pending in the Senate.

Recommendation for Legislative Action

To facilitate a comprehensive review of state land for affordable housing uses, the Legislature should require DGS to issue, by July 2023 and every four years thereafter, a report on the results of its review of state property, including a determination as to which parcels are suitable for affordable housing and the results of DGS's contact with the possessing agencies.

Description of Legislative Action

AB 2233 (Chapter 438, Statutes of 2022) requires DGS to develop, in consultation with HCD and no later than September 1, 2023, a set of criteria to consistently evaluate state-owned parcels for suitability as affordable housing sites. The bill also requires, on or before July 1, 2024, and every four years thereafter, DGS to, among other things, conduct a review of all state-owned property and identify state-owned parcels that are potentially viable for affordable housing based on those criteria. Following each review, this bill requires DGS to contact all related agencies to determine excess state land. On or before January 1, 2024, and annually thereafter, this bill requires DGS to report to the Legislature on the status of excess state properties.

California State Auditor's Assessment of 6-Month Status: Legislation Enacted

Description of Legislative Action

AB 2233 (Quirk-Silva and C. Garcia, February 2022) would require the DGS to develop, no later than September 1, 2023, a set of criteria to consistently evaluate state-owned parcels for suitability as affordable housing sites. The bill would also require DGS to conduct a review of all state-owned property and identify state-owned parcels that are potentially viable for affordable housing based on those criteria by July 1, 2024, and every 4 years thereafter. This bill would require DGS to issue a report on the results of each of its reviews. As of June 3, 2022, this bill is pending in the Senate.

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

As of June 10, 2022, this bill is pending in the Senate.

Recommendation for Legislative Action

To ensure that the SPI's reporting of state-owned property is accurate and supports the needs of the Legislature, the Legislature should require DGS to verify annually a sample of the responses agencies provide.

Description of Legislative Action

SB 803 (Becker, 2023) would require DGS to annually verify a sample of the digital inventory of excess state land suitable for affordable housing to ensure that the inventory is accurate.

California State Auditor's Assessment of 1-Year Status: Legislation Introduced

Description of Legislative Action

AB 2233 (Chapter 438, Statutes of 2022) would have required DGS to annually verify a sample of the responses provided by state agencies in response to the survey. This provision was removed prior to the bill being chaptered.

California State Auditor's Assessment of 6-Month Status: Legislation Proposed But Not Enacted

Description of Legislative Action

AB 2233 (Quirk-Silva and C. Garcia, February 2022) would require DGS to develop, no later than September 1, 2023, a set of criteria to consistently evaluate state-owned parcels for suitability as affordable housing sites. The bill would also require that DGS conduct a review of all state-owned property and identify state-owned parcels that are potentially viable for affordable housing based on those criteria on or before July 1, 2024, and every 4 years thereafter. Following each review, this bill would require DGS to issue a report on the results of its review. This bill would require also DGS to annually verify a sample of the responses provided by state agencies in response to the survey. As of June 10, 2022, this bill is pending in the Senate.

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

As of June 10, 2022, this bill is pending in the Senate Committee on Appropriations.

Recommendation for Legislative Action

To maximize the amount of affordable housing that can be created using state land, the Legislature should amend state law to allow Caltrans to sell available excess property to DGS at less than current fair market value if that property is to be used for the development of affordable housing.

Description of Legislative Action

As of April 2023, the Legislature has not taken action in the 2023-24 Legislative Session to address this specific recommendation.

California State Auditor's Assessment of 1-Year Status: No Action Taken

Description of Legislative Action

AB 950 (Ward, 2021) would have authorized the Department of Transportation to sell its excess real property to the city, county, or city and county where the real property is located, if the city, county, or city and county agrees to use the real property for the sole purpose of implementing affordable housing, emergency shelters, or feeding programs, as specified. This bill died in the Senate on August 11, 2022.

California State Auditor's Assessment of 6-Month Status: Legislation Proposed But Not Enacted

Description of Legislative Action

AB 950 (Ward, 2021) would authorize the Department of Transportation to sell its excess real property to the city, county, or city and county where the real property is located, if the city, county, or city and county agrees to use the real property for the sole purpose of implementing affordable housing, emergency shelters, or feeding programs, as specified. As of June 10, 2022, this bill is pending in the Senate Committee on Appropriations.

AB 2233 (Quirk-Silva and C. Garcia, February 2022) would authorize the Department of Transportation to sell to DGS surplus property, as defined, at less than the property's current fair market value, to the extent permissible, if the property is used for the development of affordable housing. As of June 10, 2022, this bill is pending in the Senate.

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

As of June 10, 2022, AB 950 (Ward, 2021) is pending in the Senate Committee on Appropriations.

As of June 10, 2022, AB 2233 (Quirk-Silva and C. Garcia, February 2022) is pending in the Senate.

Recommendation #5 To: General Services, Department of

To determine whether additional viable properties exist for affordable housing development, by September 2022 DGS should contact the related agencies for the remaining properties it identified as potentially viable but for which it has not yet gathered additional information and make a determination as to the viability of the parcels those agencies possess.

1-Year Agency Response

DGS and CDFA have tentatively identified six District Agricultural Associations (DAA) that may have excess property that would be suitable for development of affordable housing. CDFA is continuing their outreach to the respective DAA's to determine the availability of excess property. DGS is continuing to follow up with CSU on the status of their review of potential excess property and expects the process to be complete in March 2023.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

We are pleased that DGS has continued to work in partnership with other state agencies to identify additional property that may be suitable for development.

6-Month Agency Response

At present, DGS has conferred with the CSU, UC, and JCC, as well as the DAAs (by way of CDFA). As indicated in DGS' 60-Day Response, there is no viability for JCC sites and the program. The University of California Office of the President (UCOP), Real Estate Services and Strategies reviewed DGS' original 2019 list of potential sites. UCOP provided notes that indicated that either a) the sites were unsuitable for housing in their opinion, b) the sites were not under their jurisdiction (or in the process of being sold), c) the sites had future plans, or d) those sites that were suitable for affordable housing would be developed by the UC as faculty and/or student housing (and not through DGS). CDFA is still working with the District Agricultural Associations on excess possibilities, and DGS is awaiting a response from the CSU.

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

We look forward to DGS reviewing responses from the remaining agencies.

60-Day Agency Response

DGS has engaged in discussions with the Judicial Council (JCC), California State University System (CSU), and the University of California system. Discussions with the District Agricultural Associations will require more time. All three entities were asked to review the properties flagged in DGS' 2019 review of state properties. To date, the JCC has responded that all of their flagged properties are not excess, nor available for redevelopment as housing, while the CSU/UC are still reviewing the list of flagged properties. Additionally, while all three entities expressed a pro-housing stance on redevelopment of state properties, initial discussions indicated that DGS was correct in its assessment in 2019 that the properties of these entities were restricted or otherwise encumbered such that redevelopment into housing would be very difficult (JCC) or that DGS lacks - absent statutory changes - the authority to include these properties in the Executive Order program.

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

Recommendation #6 To: General Services, Department of

To identify additional state-owned land suitable for affordable housing development, DGS should, by September 2022, develop a set of criteria to consistently evaluate state parcels for suitability as affordable housing sites.

1-Year Agency Response

Pursuant to AB 2233 (Chapter 438, Statutes of 2022) and SB 561 (Chapter 446, Statutes of 2022) by September 1, 2023 DGS and HCD will develop evaluation criteria to determine suitability of excess sites for affordable housing; concurrently, HCD will be revisiting the screening tools that were developed pursuant to the EO.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

While there is legislation currently pending (AB 2233, Quirk-Silva and SB 561, Dodd) on the subject, it is unclear whether those bills will ultimately become law. However, DGS and HCD continue to discuss potential refinements to the screening criteria to align with changes to affordable housing funding criteria. Such an update is expected to occur by the end of September 2022.

With respect to the re-screening of state property, those conversations are ongoing, subject to the deliberative budget and legislative process.

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

60-Day Agency Response

These conversations are ongoing, subject to the deliberative budget process.

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

Recommendation #7 To: General Services, Department of

To identify additional state-owned land suitable for affordable housing development, DGS should, beginning by July 2023 and every four years thereafter, conduct and document a review of all state-owned property and identify parcels that are potentially viable for affordable housing based on the established criteria. Once this review is complete, follow up with all possessing agencies to finalize property availability. Finally, DGS should work with HCD to prioritize the identified properties for development.

1-Year Agency Response

Pursuant to AB 2233 (Chapter 438, Statutes of 2022) and SB 561 (Chapter 446, Statutes of 2022) by September 1, 2023, effective July 1, 2024, and every four years thereafter, DGS will review the inventory of all state-owned real property, applying the evaluation criteria and screening tools developed in conjunction with HCD, to identify additional excess sites for affordable housing.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

While there is legislation currently pending (AB 2233, Quirk-Silva and SB 561, Dodd) on the subject, it is unclear whether those bills will ultimately become law. However, DGS and HCD continue to discuss potential refinements to the screening criteria to align with changes to affordable housing funding criteria. Such an update is expected to occur by the end of September 2022.

With respect to the re-screening of state property, those conversations are ongoing, subject to the deliberative budget and legislative process.

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

60-Day Agency Response

These conversations are ongoing, subject to the deliberative budget process.

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

Recommendation #8 To: General Services, Department of

To increase the number of properties offered for affordable housing annually and to conduct a periodic review of all state owned properties, DGS should seek additional staffing as appropriate to provide dedicated support to the program, either by transferring existing positions or seeking a budget change for additional positions.

1-Year Agency Response

In September of 2022, DGS hired one additional Senior Real Estate Officer. Another Senior Real Estate Officer who will work on affordable housing is expected to be hired in March of 2023.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

DGS reports that it has added a staff member to support its work in affordable housing, and that it plans to add another staff member in 2023.

6-Month Agency Response

As part of the FY 2022-23 Budget Act, DGS was provided position and expenditure authority for two Senior Real Estate Officer- Specialists to work on the EO. While a funding source for these positions is still being determined, DGS contemplates filling the positions, at which time there will be five professional real estate staff working on DGS' housing program.

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

60-Day Agency Response

These conversations are ongoing, subject to the deliberative budget process.

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

Recommendation #9 To: General Services, Department of

To ensure that reporting to the SPI occurs as required, DGS should contact agencies that do not certify their SPI submissions by the deadline to determine the reasons for the delay and assist in correcting the deficiency. DGS should conduct this work annually, beginning with the reports due in December 2022.

1-Year Agency Response

DGS requested data from the departments for which their annual SPI verification submission was delinquent. These requests occurred on July 6th, August 5th, and one last time on September 8th. As of December 31st, 15 departments had not responded to the annual verification, 13 of which were District Agriculture Associations, the other two were CDT and Cal OES. Of the 13 entities, not all provided explanations for their failure to provide the annual verification. Several of the DAAs shared that they failed to report based on being busy during the summer fair season and staff shortages due to COVID. CDT let us know in early 2023 it was an oversight and was going to report on it early this year. Cal OES did not respond to our inquiries. The SPI team has sent the 2023 annual verification out on January 11th.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

DGS made several attempts to determine the reason for non-reporting by agencies, and identified rationales by certain agencies.

6-Month Agency Response

DGS requested data from departments for which their annual SPI verification submission was delinquent. These requests occurred on July 6th, and again on August 5th. As of August 5th, 19 departments had not responded to the annual verification,15 of which were District Agriculture Associations. Of the 19 entities, not all provided explanations for their failure to provide the verification. Of note, several of the DAAs indicated that their failure to provide the annual verification or explanation was due to the summer fair season and COVID quarantines. Of the remaining four entities, two were CDCR prison facilities, which indicated that their submissions were inadvertently overlooked and would be provided soon. CalOES is expected to submit their certification in August 2022, and DGS is working with CDT on timing for their submission.

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

60-Day Agency Response

The SPI team is working through the annual verification per Government Code 11011.15. Consistent with past practice, the SPI team sent a memo informing all state departments that the annual verification process was ready for viewing and access at the beginning of the calendar year, January 3, 2022. The SPI team sent a follow up email on March 15th reminding departments of the request to submit the data to DGS. Follow up emails are planned for the departments that have not submitted their SPI submissions by April 15th on May 2nd, June 1st, and June 15th, 2022. The team will request data after July 1st as to the reasons why they are late with their submittals. To the extent that departments provide reasons that are actionable on the part of DGS, DGS can address those issues as they arise.

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

Recommendation #10 To: General Services, Department of

To improve the State's ability to track public property, DGS should do the following:

- By September 2022, begin reconciling the SPI and county assessors' real property records and update the SPI as necessary.

- Ensure that county and state real property records remain in alignment by reviewing records and resolving any mismatches in the year before each periodic review occurs.

1-Year Agency Response

These conversations are ongoing, subject to the deliberative budget process.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

These conversations are ongoing, subject to the deliberative budget process.

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

60-Day Agency Response

These conversations are ongoing, subject to the deliberative budget process.

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

Recommendation #11 To: Housing and Community Development, Department of

To better promote development of affordable housing on local surplus land, HCD should, by January 2023, update its guidelines on the local surplus property law to indicate how it will respond to instances where local agencies do not notify it of their intention to sell property before disposing of it, and where DGS was unable to issue a notice of violation before the sale. Further, HCD should seek legislative changes to the extent it believes they are needed to clarify its authority or the law.

1-Year Agency Response

HCD is in the process of updating the Surplus Land Act guidelines to address the recommendations of the audit. Draft guideline language has been prepared to clarify how HCD will respond in instances where a local agency disposes of a property prior to notifying HCD.

The project schedule for the SLA Guidelines Revision process includes an internal review of needed changes (complete), drafting of a strike out and underline version of revisions (currently in progress), and a 30-day public comment and review period. The timeline for this project estimates a release of draft guidelines by April 2023.

HCD will evaulate opportunites to address audit recommendations that require statutory changes in the coming legislative session.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

HCD has made progress on updating its guidelines, and expects to release draft guidelines by April 2023.

Annual Follow-Up Agency Response From March 2023

HCD is in the process of updating the Surplus Land Act guidelines to address the recommendations of the audit. Draft guideline language has been prepared to clarify how HCD will respond in instances where a local agency disposes of a property prior to notifying HCD.

The project schedule for the SLA Guidelines Revision process includes an internal review of needed changes (complete), drafting of a strike out and underline version of revisions (currently in progress), and a 30-day public comment and review period. The timeline for this project estimates a release of draft guidelines by April 2023.

HCD will evaulate opportunites to address audit recommendations that require statutory changes in the coming legislative session.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

HCD has made progress in the revision of its guidelines and expects to release draft guidelines in April 2023.

6-Month Agency Response

HCD is in the process of updating the Surplus Land Act guidelines to address the recommendations of the audit. Draft guideline language has been prepared to clarify how HCD will respond in instances where a local agency disposes of a property prior to notifying HCD.

The project schedule for the SLA Guidelines Revision process includes an internal review of needed changes, an external stakeholder engagement and review process, drafting of a strike out and underline version of revisions, and a 30-day public comment and review period. The timeline for this project estimates a release of final guidelines by April 2023.

HCD will evaluate opportunities to address audit recommendations that require statutory changes in the coming legislative session

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

HCD has begun updating its guidelines and expects to release the approved update by April 2023.

60-Day Agency Response

o HCD has developed a draft timeline/work plan and a list of changes (including this one) to include in the update, and it is currently developing and reaching out to a list of stakeholders to engage early in the process.

o A number of current bills have proposed changes to the Surplus Land Act (SLA), including strengthening the consequences of non-compliance with the SLA. HCD is providing its analysis and input.

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

Recommendation #12 To: Housing and Community Development, Department of

To better promote development of affordable housing on local surplus land, HCD should, by January 2023, update its guidelines related to the local surplus property law to provide information on how it will assess and support good faith negotiations to mitigate the risk that local agencies may negotiate with developers in bad faith.

1-Year Agency Response

HCD is in the process of updating the Surplus Land guidelines and has included further defining and clarifying "good faith negotiations" as an item to be addressed in the update.

The project schedule for the SLA Guidelines Revision process includes an internal review of needed changes (complete), drafting of a strike out and underline version of revisions (currently in progress), and a 30-day public comment and review period. The timeline for this project estimates a release of draft guidelines by April 2023.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

HCD has made progress in updating its guidelines, and expects to release draft guidelines by April 2023.

Annual Follow-Up Agency Response From March 2023

HCD is in the process of updating the Surplus Land guidelines and has included further defining and clarifying "good faith negotiations" as an item to be addressed in the update.

The project schedule for the SLA Guidelines Revision process includes an internal review of needed changes (complete), drafting of a strike out and underline version of revisions (currently in progress), and a 30-day public comment and review period. The timeline for this project estimates a release of draft guidelines by April 2023.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

HCD has made progress in updating its guidelines and expects to issue updated draft guidelines by April 2023.

6-Month Agency Response

HCD is in the process of updating the Surplus Land guidelines and has included further defining and clarifying "good faith negotiations" as an item to be addressed in the update.

The project schedule for the SLA Guidelines Revision process includes an internal review of needed changes, an external stakeholder engagement and review process, drafting of a strike out and underline version of revisions, and a 30-day public comment and review period. The timeline for this project estimates a release of final guidelines by April 2023.

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

HCD is in the process of revising its guidelines and expects to complete the update by April 2023.

60-Day Agency Response

HCD has developed a draft timeline/work plan and a list of changes (including this one) to include in the update, and it is currently developing and reaching out to a list of stakeholders to engage early in the process.

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

Recommendation #13 To: Housing and Community Development, Department of

To better promote development of affordable housing on local surplus land, HCD should, by January 2023, increase outreach as planned to local agencies and interest groups to advise them of the notice requirements of the local surplus property law.

6-Month Agency Response

HCD has ramped up its outreach activities since December 2021 by hosting (currently 19) a series of "SLA 101" presentations to various housing and professional associations that included mentions of the Surplus Land Act. Five (5) presentations with groups including the California Association of Local Housing Finance Authorities and Contract Cities Association and has additional presentations upcoming including at the California League of Cities conference. In addition, the SLA team has submitted conference panel proposals to 3 statewide and regional housing conferences.

In July 2022, HCD released publicly available technical assistance materials and posted the resources on the Public Lands website that included the materials from the above mentioned presentations.

The external stakeholder engagement phase of the SLA Guidelines Revision project has offered additional opportunities to increase outreach and engage with stakeholders. HCD has conducted 11 listening sessions with statewide and local housing stakeholder associations, including groups representing local governments and transit agencies, and 6 listening sessions with local agencies (Cities and Counties). During these sessions, HCD has answered questions regarding the Surplus Land Act and has helped to direct stakeholders to additional resources, including technical assistance, to help in navigating how to comply with the law.

In its regular Surplus Land Act enforcement duties, HCD has submitted 612 SLA letters to agencies and districts and has conducted 478 technical assistance (TA) calls with local agencies and districts.

Going forward, HCD will begin the process of strategic planning for Surplus Land Act activities, including implementation of SB 791, that will include plans for increased outreach and engagement.

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

HCD provided us with documentation demonstrating the significant outreach it has conducted regarding local surplus property law.

60-Day Agency Response

o HCD has made progress on updating Technical Assistance materials (e.g., Frequently Asked Questions, an Exemption Guide, and an SLA 101 PowerPoint) and plans to increase awareness through the release of those materials and as part of the Guidelines outreach. More specifically, as HCD reaches out to stakeholders (including developers, advocates, and local jurisdictions) to engage on the guidelines update, it will also ask stakeholders about opportunities to present to their members and partners.

oHCD has also submitted a proposal to present at a conference hosted by the California chapter of the American Planning Association and will submit similar proposals for upcoming regional and statewide affordable housing conferences.

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

All Recommendations in 2021-114

Agency responses received are posted verbatim.