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handful to a couple hundred. She advised a shift into the thousands is unlikely but endorses going through the appeals process to exhaust the City's resources to raise objections. In response to Councilmember Narum's inquiry, Director Clark clarified that if another City wins their appeal, their reduced numbers could be reallocated to Pleasanton. She explained the primary basis of an appeal would likely be how the methodology overlooked issues of significance including job production in the South Bay and meeting the housing needs the jobs bring forth. She noted some of those housing needs seemed to flow out to the outer fringes of the Bay Area in ways that did not make sense in terms of the State's climate strategies of concentrating housing near jobs. She advised the methodology has failed on many of those points and would be compelling arguments in an appeal. In response to Councilmember Testa's inquiries, Director Clark clarified the HCD generates the RHNA. City Attorney Sodergren clarified the City's only appeal option is through ABAG for how it distributed its share of the HCD totals and not HCD itself based on a 2009 case from the City of Irvine. He reported two groups are currently challenging the HCD methodology; the first one was filed last month in Alameda County by Yes In My Back Yard (YIMBY) Action claiming HCD did not follow RHNA statutes by failing to adequately consider the Bay Area's jobs/housing imbalance, the second effort is a group of Southern California cities requesting the Southern California Association of Governments (SCAG) file suit against the State challenging the methodology. He advised SCAG has not taken any action to date. Councilmember Testa reported there are currently efforts to request a legislative audit of HCD but it is at least a year away if it does happen. In response to Councilmember Testa's inquiries, Director Clark confirmed she was one of two Alameda County representatives on ABAG's 35-member Housing Methodology Committee. She reported the City's numbers rose dramatically after September due to changes to the strategies embedded in Plan Bay Area 2050 most specifically a change in emphasis on South Bay housing production. She noted it came from an inverse strategy to encourage businesses not to overproduce jobs to avoid requirements to build housing. She reported the strategy was softened after the objection of many South Bay cities and it shifted the emphasis of land set aside for housing to jobs. She explained the redistribution of this intended housing throughout the Bay Area had a focus on redeveloping aging shopping centers and office parks. She noted Pleasanton has a lot of aging shopping centers and office parks and was tagged as an opportune location for additional housing production. She advised that Pleasanton's transit proximity, including two Bay Area Rapid Transit (BART) stations, also helped inflate the projected housing growth for the City and Tri-Valley. In response to Councilmember Testa's inquiries, Director Clark confirmed part of the methodology pointing towards Pleasanton is access to high-opportunity areas. She advised the equity adjustment was requested by members of the pro-housing community for areas where the methodology by itself did not address allocation of lower-income units to higher opportunity areas. She advised Pleasanton was not affected by the equity adjustment because it was perceived to already meet the equity goal. She reiterated the increase is not a result of the equity adjustment. In response to Councilmember Arkin's inquiry, City Manager Fialho confirmed there is currently $15 million in the City's Affordable Housing Fund. In response to Mayor Brown's inquiry, Director Clark clarified ABAG assumes Plan Bay Area 2050 counts the existing building capacity. She advised some cities are highly constrained in terms of fire risk, water supply, and other factors and noted available space is built into the process. She explained her simplified interpretation of the process is HCD and ABAG gives the City a number and the City must figure out where to put the units. She advised the City will have to redevelop developed properties to meet this anticipated number for lack of vacant land. City Council Minutes Page 5 of 15 March 16. 2021