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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 City Council with flexibility to adjust the list as the project moves through various stages of review and according to various comments and inputs, including community feedback, HCD review and comments, and the environmental analysis.4 In addition to flexibility through the Housing Element process, developing a broader list could help address "no net loss" provisions of state laws, by allowing the City to structure the Housing Element to either include a "buffer" of extra residential zoning capacity among the sites identified; 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, that have already been through the necessary CEQA review. At this early stage, staff recommends identifying 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 with adoption of the Housing Element. Densitv Assumotions for Initial Inventory In addition to a larger total number of sites included in the initial inventory, staff recommends taking a relatively conservative approach in the estimation of zoning capacity for the sites, using an "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. Based on guidance provided by HCD for higher -density housing sites, the inventory needs to reflect a realistic capacity that takes account of aspects like physical constraints, necessary on-site infrastructure and circulation, parking, and development standards like height and setback requirements. Using an average density or minimum density for high-density sites will help to align the initial inventory with these realistic capacity assumptions going forward, and not be overly aggressive in the assumed capacity for particular sites. Hiah Densitv Housina and Minimum Default Densities State law provides for a series of "default densities," which are zoning minimums that, if applied, can be assumed to yield lower-income housing units. In communities like Pleasanton, the minimum default density for units to be counted as lower-income units in the inventory is 30 du/ac. HCD guidance also suggest that a size range between 0.5 acres and 10 acres are most realistic to assume as developing with higher -density and lower-income units. Per HCD guidance, sites zoned between 20 and 29 du/ac, and of at least 0.25 acres in size, may be assumed to yield moderate -income units. a A key aspect is timing of the CEQA review process, which needs to be initiated early in the overall Housing Element process, and even before the Draft Housing Element is submitted to HCD for its initial review, so it can be completed by the date of Housing Element hearings for adoption. Therefore, the CEQA analysis will address a broader list of sites than may ultimately be included in the adopted Housing Element. 5 "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. Housing Element Update Planning Commission 6of19