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the needs of low- and very-low income households) and 14 acres at 23 units per acre (meeting the needs of moderate income households). On October 14, 2011, the City received comments on the Draft Housing Element from HCD addressing several aspects of the Draft Housing Element. The majority of the letter requests additional technical information and analysis that is currently being incorporated by staff into a subsequent draft. One of the comments from the letter addresses the subject of the sites to be rezoned. Essentially, HCD is questioning the City's assumption that the rezoning of the three Hacienda sites (which the City approved in March 2011) can be counted towards fulfilling the housing needs for very-low and low- income households. Based on State housing law (Sec. 65583.2(c)(3)(b)(iv)), which allows the City to use a default density of a 30 units per acre minimum as meeting the needs for lower income households, the City allocated the 870 units (which would be developed at the minimum 30 units per acre density) equally between the low- and very-low income categories. HCD's comment requested additional analysis to demonstrate the availability of these sites to accommodate the lower-income household need, and to describe the development status of the sites, whether there are any approved or pending projects and what other conditions are known that would preclude the sites from accommodating the lower income housing need. Although not directly asserted by HCD, the implication is that as the City is now reviewing applications from BRE on two of the sites, only the income-restricted units on these sites can be counted towards the low income need as we now know that the remainder of the units on these two sites will be market rate (affordable to moderate income households). HCD's assertion that only the income- restricted units can be counted towards the low income need once a development project has been submitted for review on that site is currently under review by the City. It is staffs recommendation at this time that the City Council consider a list of sites that would include an additional 14.3 acres, over and above the 69 acres described in the Housing Element Background, or a total of approximately 84 acres. If the City Council later decides not to address HCD's assertion in this matter, it can further pare down the list of sites prior to taking any formal action. DISCUSSION Much of the work of the Housing Element Task Force was focused on the identification of sites to accommodate the City's need for additional multifamily housing as identified in Table III-1 of the Housing Element Background. As noted, the need for additional rezoning includes 55 acres at 30 units per acre (a density appropriate to meet the low and very-low income household need) and 14 acres at 23 units/acre (a density suitable for meeting the need for moderate income households). The Task Force undertook extensive community outreach at four community meetings and provided a forum for neighborhood discussion about the sites at all nine Housing Element Task Force meetings. During this review, the Task Force considered approximately 35 sites. Through the public outreach process and evaluation of the sites using a number of site selection criteria, the list of 17 sites in Table 1 was recommended for inclusion in the draft Page 3 of 8