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Citizens for a Caring Community P.O. Box 1781 , Pleasanton CA 94566 S1 L ME1TAL MATERIAL l/larch 1, 2014 Pleasanton City Council �'• " P.O. Box 520 Provided to the City Council Pleasanton, CA 94566 After Distribution of Packet Re: Council Agenda for March 4,Agenda Item 9 ;rate Dear Mayor Thorne and City Councilmembers, Citizens for a Caring Community (CCC) has reviewed the Staff Report (SR)for Agenda Item 9. We strongly disagree with staff's recommendation for City Council to certify that the Pleasanton has enough High Density Residential (HDR) zoned land to comply with Regional Housing Needs (RHNA) requirements for the 2014- 2022 planning period. We believe that staff has grossly overstated the percentage of affordable units (100%) likely to be accommodated on un-entitled land, and that it would be premature for Council to make this finding without first adopting changes to Housing Element policies and programs that would ensure this outcome. In addition, our analysis shows that the East Pleasanton Specific Plan (EPSP) cannot feasibly develop without creating more demand for affordable workforce housing than it can provide. CCC reached these conclusions based on the legally required process outlined by staff on page 2, which calls for"...a review and eva uation of programs and policies in the previous element, looking at the effectiveness of the element and how the policies and programs could be amended and refined..." The SR's Table 3 contains the information needed to evaluate the success of the current Housing Element (HE) policies and programs. We have restated this information below, (Table A) focusing on the percentage affordable unit yield from approved development of land zoned HDR. Table A includes a restatement of Below Market Rate (BNIR) unit yield for each approved project in each affordability category. In addition, Table 3's affordability categories have been corrected to reflect the Affordable Housing Agreements (AFAs) for these projects, consistent with the actual range of unit affordability each developer has agreed to provide. Table A: Residential Projects With Development Entitlements Without Building Permits Or Not Occupied As Of 12/31/2013 Entitled Sites 0-49% 50% 51-79% 80% 81-120% >120% TOTAL Auf der Maur 0 10 (3%) 0 17 (5%) 318 (92%) 0 345 CA Center 0 8 (3%) 0 15 (5%) 282 (92%) 0 305 Pls Gateway(30 du/acre) 0 16 (8%) 0 16 (8%) 178(82%) 0 210 St. Anton Hacienda 0 18(14%) 0 18 (14%) 132 (64%) 0 168 Total Entitled Units 0 52 0 66 910 0 1,028 % BMR units achieved 0 5% 0 6% 89% 0 100% For the next step in determining the "effectiveness of the Housing Element" in fulfilling RHNA with the residentially zoned land available, we estimated the probable results, based on the City's past experience, in applying the current HE policies and programs to the land available for HDR/BMR residential development in the next planning period (2014-2022). Because staff has proposed no changes in HE policies or programs designed to generate a much higher percentage of affordable units in future developments, the ratio of BMR units to market rate units should remain approximately the same.Table B, using information from SR Table 2 and percentages calculated in Table A, demonstrates the likely result of applying the current HE policies to future HDR developments: