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The preliminary estimated capacity for each site/area is shown in Table 4, allocated into the various affordability categories. For the purposes of this analysis, all high-density sites (30+ du/ac) are assumed to generate lower-income housing units, as allowed by state law. On this basis, if all 29 initially -identified sites were to be retained and move onto the CEQA consideration, they would be able to conservatively accommodate a total of 6,629 units, including 4,109 very low- and low-income units (high-density sites) and 2,520 above moderate -income units3. Compared just to the baseline "gap," using all of the sites would yield more than twice the total number of units needed, including more high density units than needed to meet the lower-income RHNA. However, as previously noted, the Planning Commission supported the inclusion of a "capacity buffer" in the initial inventory of at least 50 percent, to provide a conservative basis for the CEQA analysis and allow flexibility to refine the list based on future inputs. Inclusion of this buffer would result in the need to identify sites sufficient to accommodate at least 4,715 units (3,413 plus a 1,572 -unit buffer). Therefore, considering all 29 sites, estimated to yield a total of 6,629 units, there would be a surplus even beyond the "50 percent capacity buffer" of approximately 1,914 units. For high-density sites, the yield of units would also exceed that needed to accommodate the lower-income RHNA. Based on the above capacity analysis, staff suggested, and the Planning Commission concurred, the following guiding parameters in developing the initial inventory: • The City can, and should, assume that at least some portion of its moderate- and above -moderate RHNA will be accommodated on high-density sites, not just lower- income RHNA. • Although high density sites alone could accommodate the entire RHNA4 (exclusive of the buffer), having at least some sites designated at densities below 30 du/ac would provide more flexibility in building the inventory and accommodate a greater diversity of housing types for different household types and sizes. • There is considerable flexibility, with a surplus of over 1,500 units (even when accounting for the buffer) to adjust the overall sites list at this stage - i.e. eliminate some sites from consideration; and/or adjust density/capacity assumptions downward. 3 As a conservative estimate, staff is assuming the average density, for the low and medium density sites rather than the maximum or top of a density range and a minimum 30 dwelling units per acre (du/ac) for the high density sites. High density sites could accommodate 4,109 units, 966 units above the projected shortfall/gap. 11 of 18