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Estimate of Site Capacity and Units at Various Income Levels The overall preliminarily -estimated capacity for each site/area is shown below in Table 5, 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 and 2,520 above moderate -income units2 Considering total units, the capacity generated by all sites exceeds the projected shortfall/gap (3,143 units), by around 3,486 units. However, as previously noted (and supported by the Planning Commission) staff recommends the initial sites inventory build in a buffer of capacity that is at least 50 percent beyond what would be needed strictly to address the existing zoning shortfall, 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) — considering all 29 sites, there would be a surplus of approximately 1,914 units. In the November 10 Agenda Report, staff provided some initial conclusions with respect to the overall inventory and capacity. Although these conclusions still generally hold true, based on the addition of the SteelWave and Oracle sites, there is now a greater opportunity to consider accommodating above -moderate RHNA on high-density sites, and more flexibility to eliminate some further sites from consideration. Updated guiding parameters are as follows: • 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. (The Planning Commission did not object to this concept.) Although high density sites alone could accommodate the entire RHNA (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. (The Planning Commission agreed with this approach, although it also emphasized production of higher density and affordable housing.) • There is considerable flexibility, with a surplus of over 1,500 units (even with addition of a buffer) to adjust the overall sites list at this stage (i.e. eliminate some sites from consideration), and/or adjust density/capacity assumptions downward. 2 A a conservative estimate, staff is assuming the average density of all recommended density ranges at this stage in the evaluation. Housing Element Update Planning Commission 9of14