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070253\14264881v7 <br /> <br /> <br /> <br /> <br /> <br />3 <br /> <br />requirements. We briefly address each of these below: <br /> Site Size and Location: The portion of the Steelwave Site under consideration is <br />approximately 123 acres and is similar in size to other sites recommended for <br />inclusion in the Inventory, a number of which range from dozens of acres to over <br />100 acres in size. As with the Steelwave Site, other sites recommended for <br />inclusion would also require annexation into the City. <br /> <br /> Adjacency to Industrial Development: The Steelwave Site is located adjacent to <br />the site for a proposed Amazon distribution facility. Other sites recommended <br />for inclusion in the Inventory are similarly located adjacent to industrial uses, <br />thereby demonstrating compatibility between such uses and residential <br />development. <br /> <br /> Land Use Planning Requirements: Developing the Steelwave Site would require <br />infrastructure and circulation planning, and the Site would be developed for <br />mixed uses. Other sites recommended for inclusion in the Inventory will similarly <br />require infrastructure and/or circulation planning and will result in the <br />development of mixed uses. Further, as discussed in more detail in part C below, <br />the City has already completed extensive planning for the Steelwave Site <br />through the EPSP planning process. As a result, the City’s prior EPSP planning <br />work would act as a springboard for current planning efforts for the Steelwave <br />Site. <br />As summarized above, the Steelwave Site would not pose planning challenges greater <br />than those of other sites recommended for inclusion in the Inventory.2 As with those sites, we <br />believe these challenges can be adequately addressed for the Steelwave Site, and that they do <br />not justify its exclusion from the Inventory. As a result, we believe City planning staff’s <br />assessment of the Steelwave Site significantly overstates the challenges of completing <br />necessary planning for Site within the Housing Element Law’s required timeline. <br />C. The Steelwave Site is “suitable and available” for housing development, and <br />including it in the Inventory would reduce the City’s reliance on nonvacant <br />sites to meet its RHNA. <br />The Housing Element Law requires the City’s Housing Element Update to include an <br />inventory of land “suitable and available for residential development.”3 Among other things, to <br />demonstrate sites included in the Inventory are “suitable and available,” the City must consider <br /> <br />2 Please also see our letter dated November 16, 2021, attached to this letter as Attachment 2, in which we describe <br />why we believe the Steelwave Site should have scored much higher under the City’s Site Selection Criteria. <br />3 Government Code § 65583(a)(3).