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SUPPLEI1 NT8L MATERIAL Citizens for a Caring Commun vldt3it to the City Council P.O. Box 1781 , Pleasanton CA 94566 f of eiOltibution of Packet D4k .6 u January 5y-2 Mayor Thorne and Pleasanton City Council Members Pleasanton CA 94566 Re:Agenda Item 7.2015-2023 Housing Element: Responses to comments on the Draft HE by Citizens for a Caring Community(CCC) Dear Mayor Thorne and City Councilmembers, After reviewing the amended Housing Element,CCC wishes to state, for the record,that we do not fmd the City's evaluation of our comments submitted to HCD on the Draft Housing Element responsive to the issues we raised. In addition to containing some misstatements of fact, the City asserts new,lower standards of compliance with State housing law, and indicates its intention to avoid the implementation of any new policies or regulations that would facilitate fulfillment of its RHNA obligations or prevent its continued discrimination against nonprofit developers of housing for lower income workforce households. Please find our comments below. Beginning on Page 3 of Exhibit H, under"Public Comments Received during HCD Review Period":. "Staff has acknowledged the changes to the IZO are needed and has incorporated Program 17.1 which states: Program 17.1:Review the City's Inclusionary Zoning Ordinance and amend:..." The first three sub-programs contained in Program 17.1 are exactly the same as the three sub-programs in Program 16.2 of the 2007-2014 Housing Element. In April 2013,in accordance with Program 16.2, the Housing Commission determined that Pleasanton's court invalidated IZO produced too few affordable units to be consistent with the City's affordable housing programs. Because inclusionary zoning was no longer legal, the Housing Commission found it appropriate to replace Pleasanton's IZO with more effective policies and requirements in the 2015-2023 Housing Element. However, the City took no action to implement their recommendation. Instead of undertaking the warranted comprehensive rewrite of regulations to ensure RHNA compliance, staff added a fourth sub-program to the old Program 16.2, now Program 17.1: "- (amend the IZO)to be consistent with recent court decisions regarding rental housing and State law." This additional condition for amending the IZO clearly signals the City's intention to continue to prefer for- profit development with very few or no affordable units on parcels zoned HDR rather than facilitating nonprofit development that would make a greater contribution to meeting Pleasanton's affordable housing needs consistent with its RHNA obligations. The City justifies retaining the 2007-2014 programs and policies on page 4 of Exhibit H,stating that: .. analysis indicates that the City has been successful in using programs and incentives to develop market-rate housing projects with substantial affordable components,particularly at the high density sites." Staffs claim to have achieved"substantial"affordability in for-profit projects using the IZO and other programs carried over from the previous Housing Element completely ignores HCD's requirements to measure Housing Element performance in terms of achieving RHNA assigned levels of affordability. In this respect staffs assertion that it provided"substantial affordable components" in for-profit developments does not respond to CCC's comments and concerns.A review of the facts demonstrates staffs claims of"success"to be greatly overblown. In the 2007-2014 planning period Pleasanton approved 4 HDR projects consisting of 1,028 apartments. Very Low Income Low Income Moderate (Market Ratel Pleasanton RHNA 2007-2014 1,076 728 720 Entitled 2007-2014 42 (3.9%) 49 (6.7%) 937 (130%)