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Page City IZO negatives: • The 15%inclusionary requirement cannot generate enough units or depth of affordability to fulfill RHNA identified housing needs. • The 15%IZO requirement may not even mitigate the need for affordable housing generated by the remaining 85%of market rate units. • The IZO only provides units affordable at the very top of the Low and Very Low income range. Households earning 51%-79%AMI,or below 49%AMI will not have enough income to qualify for rent restricted units provided by the IZO. • The IZO allows Moderate Income units(80-120%AMI)to be counted as part of the IZO requirement. Periods of high vacancy and/or low demand often result in these units having higher rents than unrestricted units in the same complex • Pleasanton can only use the UHF to assist a developer in providing more affordability in apartment projects if the developer is willing to pay prevailing construction wages.The value of incentives offered by the IZO appears insufficient to overcome the financial benefit of using non-union labor. • Timing of Affordable Housing Agreement Approval-Section 17.44.060. Specifying only that the Housing Agreement will be recorded before the final map implies that determinations about how a project will provide affordable units follows approval of project design.On land rezoned in response to RHNA and the Housing Element approval process, the City should first focus on evaluating how an applicant's preliminary concept can use options provided by an IZO to yield the greatest number of affordable unit&.The City should not process more detailed design plans until AFTER the applicant and staff have completed this evaluation and made a report to the Housing Commission and Cornell. • The IZO option requiring rent restricted units to be scattered throughout a market rate project limits the number of affordable units as well as the depth of their affordability.The developer's ability to subsidize lower rents in perpetuity constrains the City's ability to use the land to meet its housing needs.The IZO's other options could actually provide more affordable'units than 15%of a project's market rate units.Therefore,defining 15%as the base affordability requirement is problematic because it undercuts the City's ability to meet RHNA numbers. Developer IZO positives: • Not having to pay LIH fee. • The ability to include Moderate Income units as affordable,which rent at about be market rate, while not having to pay the LIHF. • Rent restricted units only need to be affordable to households earning at the top of 50%AMI, 80%AMI,and 120%AMI income categories.