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page 2 This result shows policy failure. Pleasanton's self-congratulation and decision to retain housing programs that produced such a small number of affordable units is evidence that Pleasanton intends to pursue land use objectives without regard to its regional housing responsibilities. Staff goes on to state that the"incorporation"of Program 17.2 requiring annual monitoring for performance, ensures"...the IZO will continue to be a successful tool for providing affordable units."By defining past failure as success, staff implies BCD's passive approval for replacing RHNA with the much lower standard of Pleasanton's past performance. If this is the new standard of success, the development of Pleasanton's entire 2015-2023 HDR inventory of 934 apartments will yield even fewer affordable units. Very Low Income Low Income Moderate(Market Ratel Pleasanton RHNA 2015-2023 713 389 405 Entitled 2015-2023 28 (3.9%) 26 (63%) 934(217%) Staff offered no response to CCC's comments regarding the Lower Income Housing Fee other than saying that, in 2013, the Council decided not to raise the fee due to "economic conditions". Staff has not explained the change in circumstances which led to the Council's September 2014 decision to impose quadruple the affordable housing in- lieu fee (from$1 million to$4.5 million) on a for-profit development that wanted to avoid including affordable units. It appears that even a fee much higher than that proposed in 2013 will not negatively inhibit new development in Pleasanton. Because the balance of the LIHF is currently inadequate to support construction of the units required to fulfill Pleasanton's RHNA,staffs response to CCC's comments should also include justification for the Council's decision to divert $3.5 million of this in-lieu payment to uses other than affordable housing. Beyond their assertion that the programs and incentives to encourage provision of affordable units in for-profit projects have resulted in so much new affordable housing that no changes arc needed,staff also asserts that "...in the long-term, these programs will help nonprofit developers successfully build affordable housing because they address the basic economic impediments to housing construction that are faced by both for-profit and nonprofit developers." Their conclusion that the current policies are acceptable because they will facilitate nonprofit housing"in the long term"is contrary to the City's obligation to plan to achieve RHNA within the planning period. In addition,staff asserts,incorrectly, that its affordable housing incentives address"economic impediments" that are the same for both for-profit and nonprofit developers. In fact,due to its many years of successful work with nonprofit developers, staff knows well that nonprofit housing providers face very different challenges than for-profit developers. Comparing Pleasanton's current assistance to nonprofit Mid-Pen on low income senior housing, including land dedication, property acquisition, a citizen task force, and a substantial contribution from the LIHF demonstrate that that difference. It also shows that Housing Element policies constitute a significant barrier to the nonprofit development of affordable workforce housing. This violates Pleasanton's Resolution 10-390 which requires that "In recognition of State and Fetal laws which prohibit municipalities from discriminating against developers of affordable housing, including nonprofit developers of affordable housing, and from discriminating against families with children in need of affordable housing...the City staff and the City Council will act affirmatively to promote the development of well-designed affordable housingforfamilies with children in Pleasanton..." Pleasanton's solicitation of a nonprofit builder to develop senior affordable housing in the near term,including provision of incentives well beyond those offered in the Housing Element is laudable. However, Pleasanton's failure to use the same methods to secure nonprofit builders to develop low income housing for families with children in the same near term time frame constitutes discrimination. Staff has not addressed CCC's comments about the differences in the way the City plans to allocate resources to facilitate nonprofit senior and family lower housing.