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whereas projects at and above 40 DUA can support integrated, structured parking, leaving more of the site available for on-site open space and amenities. Sites zoned at higher densities would yield more units, thus requiring less land to be rezoned and may offer more favorable site design outcomes. Accordingly, the City may wish to consider zoning selected sites (for example, sites located with a half mile of BART) at densities above 40 DUA, assuming the projects could be designed in a manner that met community standards and expectations, and impacts appropriately mitigated. • Secondary/Contingency List: Given the provisions of SB 166, the City may wish to consider creating a secondary or contingency list of sites to be considered for re- zoning, if and when needed, to address No Net Loss provisions. • Zoning "Buffer": It may also be beneficial for the Sites Inventory to include a "buffer," similar to or larger than that included in the 2015 Housing Element, to account for the fact that not all sites may remain viable throughout the Housing Element period, and thus providing some flexibility in meeting RHNA goals and no net loss requirements. (This strategy could also help to address the "No Net Loss" issue as well, instead of or in addition to the secondary list of sites discussed above). • Density and Site Development Assumptions: The 2015 Housing Element took the general approach that lower-income units would be accommodated on higher- density sites (e.g. as apartments and condominiums) and that moderate and above- moderate income units would be accommodated on low- and medium density sites (e.g. as detached and attached single-family units like townhomes). In this cycle, and particularly given the likely need to identify sites for moderate- and above- moderate housing, the Housing Element could consider alternative approaches, such as allocating a share of the moderate- and above-moderate need to higher density sites and in multi-family developments.4 • Distribution of Sites and Units: In the current and prior Housing Element, a policy guideline for selection of sites was to try and distribute sites, particularly higher density sites, throughout the community. In recent discussions with City Council regarding the Housing Element, there remains a commitment to this approach, to avoid overconcentrating larger projects and potential impacts within only certain parts of the city. • Promoting Affordability: As discussed, while market-rate housing has been built at levels over and above the RHNA targets, it has been much more challenging to produce below-market-rate (BMR) and affordable housing. The Housing Element a Note that legislation recently approved(AB 725 (Wicks))and will require a portion of moderate-and above- moderate RHNA to be accommodated on multi-family sites. Page 9 of 10