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Sites Inventory and No Net Loss Provisions To meet the new RHNA, it will be necessary for the City to identify and ultimately rezone a number of parcels throughout the city. The project scope of work includes a multi-step process to 1) inventory existing sites and evaluate the "gap" to be addressed through identification of new sites; 2) determine the criteria, preferences, and priorities in identifying sites (building upon the requirements of State law, and verification of Pleasanton-specific criteria) and allocating appropriate densities; and 3) identify, select, and rank additional suitable sites for inclusion in the Housing Element. The sites analysis process is made more challenging and complex in this cycle due to changes in State law that provide more stringent criteria for identification and selection of sites. And, more limitations exist around the re-use of high density housing sites included in previous cycles, although staff expects that a number of these sites can be "re-used" in the 6th Cycle inventory. Even with a carryover of sites from the prior Housing Element, a substantial inventory of new sites is likely to be needed to be developed. A very preliminary analysis, based on the draft RHNA in the range of 6,000 units, suggests that 250 or more acres may need to be identified and/or re-zoned for housing this cycle, at various densities and affordability levels. This estimate assumes that approximately 1,000 units (in various income categories) could be "carried over" from the prior inventory3; and that the remainder would be accommodated on sites at various densities. The State's recently updated and more stringent "no net loss" provisions (through the Housing Accountability Act/SB 166 (HAA)) also raise strategic questions about how to formulate the sites inventory. Under the HAA, if the approval of a development project results in fewer units by income category, the jurisdiction must identify additional sites to accommodate the RHNA obligation lost as a result of the approval (including re-zoning of sites if insufficient capacity exists in the inventory). Although State law allows for sites zoned at certain minimum densities to be counted for the purposes of the sites inventory as providing exclusively affordable units, in practice, most higher density developments have built predominantly market-rate units, leaving a remainder to be accounted for elsewhere in the inventory. These factors will result in some strategic questions and decisions as the inventory is developed, outlined in the list below. Other Strategic Considerations Given these challenges, some of the key strategic and policy considerations that will need to be part of the Housing Element sites analysis and selection process, include: • Housing Densities: The minimum density considered by the State to produce low- and very low-income units (in communities such as Pleasanton) is 30 DUA. In the prior Housing Element, the majority of high-density sites were zoned at this density, with a few sites at 40 DUA. In this cycle, it may be beneficial to consider zoning more sites at, or even above, 40 DUA. As has been seen with recent developments in Pleasanton, projects built at 30 DUA or less will generally be surface-parked; "Carryover"units may include those counted on sites already zoned for housing, or that have planning approvals in place, but the units have not actually yet been constructed. Page 8 of 10