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Several variables will affect the amount of land that may need to be identified for re-zoning,
<br /> including the number of sites eligible to be "carried over" from the prior inventory that were
<br /> identified to accommodate the low- and very low-income units, assumed density for each site,
<br /> assumed affordability levels, and potential constraints that might require adjustment to the
<br /> capacity of certain sites, to a level that HCD would consider realistic. Specifically, "carryover"
<br /> sites would be required to maintain their originally designated minimum densities, provide at a
<br /> minimum, 20 percent of the units designated as affordable to lower income households, and to
<br /> allow residential uses "by right6".
<br /> Recent changes to state law have also made the analysis and requirements for identifying
<br /> sites more challenging than in previous housing cycles, with an expansive list of criteria that
<br /> must be used to demonstrate to HCD that sites, particularly non-vacant sites, are viable and
<br /> suitable to be included in the inventory. New non-vacant sites must include descriptions that
<br /> include the specific existing use on the site, such as an office building, restaurant, single family
<br /> residence, nursery, etc. Additional details, such as whether the use is discontinued, land to
<br /> value information, age and condition of the structure, known leases, developer or owner
<br /> interest, whether the property is currently being marketed, degree of underutilization, etc., will
<br /> also be required. Analysis to determine the development potential would then be required that
<br /> includes development trends, market conditions, and availability of regulatory and/or other
<br /> incentives. Such research and analysis for each new non-vacant site will be tedious and take
<br /> substantial research and time.
<br /> Based on a review of these, and other criteria, staff believes that some of high-density sites in
<br /> the current inventory will be unable to be carried over to the next cycle: however, every effort
<br /> will be made to utilize these sites if possible.
<br /> A very preliminary analysis, based on the draft RHNA in the range of 6,000 units, suggests that
<br /> 250 or more acres may need to be identified and/or re-zoned for housing this cycle, at various
<br /> densities and affordability levels. This estimate assumes that approximately 1,000 units (in
<br /> various income categories) could be "carried over" from the prior inventory'; and that the
<br /> remainder would be accommodated on sites at various densities. While the number of acres
<br /> required to be re-zoned could be higher or lower based on multiple factors, it is nonetheless
<br /> likely to be significant. It is difficult to provide an exact comparison between the prior and
<br /> current cycle; however, the total inventory for all sites included about 594 acres8; of this,
<br /> 87 acres were included as High-Density Housing sites, yielding a total of 1,711 units.
<br /> No Net Loss Provisions
<br /> Another major factor to be considered in the inventory, is the effect of the more stringent "no
<br /> net loss" provisions that were adopted by the State in 2017, via Senate Bill 166 (SB 166).
<br /> 6 By right means the jurisdiction shall not require: 1.)A conditional use permit.2.)A planned unit development permit.3.)
<br /> Other discretionary, local-government review or approval that would constitute a"project"as defined in Section 21100 of the
<br /> Public Resources Code(California Environmental Quality Act"CEQA").
<br /> "Carryover"units may include those counted on sites already zoned for housing,or that have planning approvals in place,
<br /> but the units have not actually yet been constructed.
<br /> This acreage is quite substantial, in part because the Housing Element's inventory lists the acreage of the entire parcel
<br /> identified,when in many cases only a portion would include the housing development.For example:the Stoneridge Mall
<br /> property is listed as a 74.6-acre site,where only 10 acres of the parcel was actually zoned/designated for housing. The Lund
<br /> Ranch property encompassed 123 acres,with much of that area ultimately dedicated as open space, and a much smaller area
<br /> ultimately developed as single-family housing.
<br /> Housing Element Update Planning Commission
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