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parcel -specific inventory, that there are sufficient sites available today to accommodate the entirety of its RHNA. If the City does not have enough adequate sites currently zoned to accommodate the assigned RHNA, additional sites will need to be identified and ultimately rezoned. The adequacy of the sites inventory will be evaluated by the State Department of Housing and Community Development (HCD). Although HCD will review the entire inventory, it pays particular attention to sites identified to accommodate the City's lower-income RHNA, based on criteria intended to show the various sites' realistic capacity to develop during the eight-year planning period of the Housing Element. It is important to note that the identifying sites to accommodate the RHNA is a planning exercise; it is not a mandate or quota for the City to construct housing units. While the City must report annually on production of housing relative to its RHNA numbers, there are no direct penalties for failing to meet the allocation; however, recent State law has implemented streamlining and reduced local discretion over approval of housing projects, some of which is specifically targeted at jurisdictions whose housing production has fallen short of the RHNA. ANALYSIS OF EXISTING ZONING CAPACITY AND SHORTFALL OF SITES The following outlines the City's draft RHNA, the components that make up the current sites inventory, and how the projected shortfall is calculated. Draft Regional Housing Needs Allocation Table 1 summarizes the draft RHNA for the City of Pleasanton, as published by the Association of Bay Area Governments (ABAG) in May 2021.' The RHNA is distributed among four income categories, each of which represent relative affordability to households as a proportion of the Countywide Area Median Income (AMI). Table 1: Draft RHNA Income Category Aw Extremely Low Income (ELI)* Very Low (VLI)* Low Income (LI) Moderate Income (MI) Percentage of Area Draft RHNA Median Income <30% 1,750 31-50% 51-80% 1,008 81-120% 894 Above -Moderate Income (AMI) >120% 2,313 _ Total 5,965 Units " The RHNA does not split out Extremely -Low and Very -Low Income Units; however, jurisdictions are required to account for both categories in the Housing Element's Quantified Needs Assessment, typically assuming and even split between units in each income cateaorv. The ABAG Administrative Committee is scheduled to ratify its initial determinations on appeals of the Draft RHNA on November 12, and the ABAG Board is scheduled to adopt the Final RHNA in mid-December. Housing Element Update Planning Commission 3of19