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The sites selection process will entail a progressive narrowing or refinement of the inventory list. Therefore, at this relatively early stage, it is recommended that a broader inventory of sites be identified, with a total capacity beyond the shortfall estimate. Providing a broader range of sites will provide the City with flexibility to adjust the list as the project moves through various stages of review. Later in the update process, and prior to the final adoption of the Housing Element in early 2023, the City Council has the ability and discretion to decide the final list of sites to include in the inventory. In concept, the inventory could include more sites than strictly necessary to meet the RHNA. In the 6t" Cycle, many cities are opting to include this type of "buffer" of additional sites capacity, particularly in light of the more stringent "no net loss" provisions of state law'. Pleasanton could choose to either include a built-in "buffer" of extra residential zoning capacity among the sites identified and adopted as part of the Housing Element; or to create a list of potential additional sites that are not included in the Housing Element at the time of adoption, but eligible to be considered at a future date for rezoning if needed. By including them in the CEQA analysis, and otherwise vetting them through a public process that deems the sites conceptually suitable for housing, this "back up" list will simplify the process of selecting future sites in the event that additional re - zonings are needed to address "no net loss." Following this approach, at this early stage of the site selection process, the Planning Commission supported staff's recommendation to identify sites with zoning capacity sufficient to provide at least 50 percent more units than the identified gap (i.e. approximately 4,715 units), understanding that this will ultimately be narrowed to be closer to the actually needed number of sites, following the CEQA analysis and with adoption of the Housing Element. Default Densities and Capacity Assumptions, The inventory process requires the City to identify the density ranges at which each site will be developed. As discussed below, staff has recommended potential densities for each site, including low, low/medium, medium and high density ranges, assigned based on location and other site characteristics. With respect to the various income categories for which the inventory must show adequate capacity, State law provides for a series of "default densities" which are zoning minimums that, if applied, can be assumed to yield lower-income housing units2. In communities like Pleasanton, the minimum default density for units to be counted as lower-income units in the inventory is 30 dwelling units per acre (du/ac) and between 20 and 29 du/ac to be counted as moderate -income units. Although the City may count all units in the inventory zoned at 30 units per acre or more as affordable or lower-income (or t "No net loss" provisions are a component of the Housing Accountability Act, which, whenever a project is approved with few units, or less affordability than cited in the Housing Element, requires findings to be made that adequate zoning capacity remains in the inventory to accommodate the units not built, or for the City to re -zone additional sites to accommodate that number of units. 2 Additional site size requirements also apply, see Attachment 1 for more information. Page 4 of 18