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070253\14264881v7 <br /> <br /> <br /> <br /> <br /> <br />4 <br /> <br />the availability of infrastructure, whether environmental constraints would preclude residential <br />development on sites included in the Inventory, and whether existing uses on nonvacant sites <br />in the Inventory may impede residential development.4 As described in more detail below, the <br />City’s extensive EPSP planning efforts to date include detailed infrastructure planning for the <br />Site and demonstrate that there are no environmental constraints that would prevent the <br />development of housing on the Site. Further, as a vacant site with demonstrated owner interest <br />in residential development, the Steelwave Site would balance out the City’s heavy reliance on <br />nonvacant sites in the Inventory, thereby improving the proposed Housing Element Update’s <br />defensibility. <br />1. The City has already completed infrastructure planning for the <br />Steelwave Site. <br />The Housing Element Update’s Sites Inventory must only include sites for which <br />sufficient water, sewer, and dry utilities are available or have been planned for.5 Through its <br />most recent EPSP planning efforts, the City already completed extensive infrastructure planning <br />for the Steelwave Site. The latest draft of the EPSP includes a potable water plan, recycled <br />water plan, sanitary sewer plan, storm water drainage plan, and dry utilities planning for the <br />EPSP area, including the Steelwave Site.6 These plans could easily be incorporated into the <br />City’s Housing Element Update to satisfy the Housing Element Law’s infrastructure availability <br />requirements. <br />2. There are no environmental constraints preventing residential <br />development on the Steelwave Site. <br />The Housing Element Update must demonstrate that environmental constraints will not <br />prevent residential development on sites included in the Inventory.7 For the Steelwave Site, the <br />City’s Draft Environmental Impact Report for the EPSP demonstrates the Site does not contain <br />any environmental constraints that would impede residential development. As shown on <br />Exhibit 3.3-3 of the EPSP Draft EIR, the Site is dominated by disturbed land and non-native <br />grassland.8 Potentially valuable habitat on the eastern portion of the Site is proposed to be <br />protected from development as a public park.9 The EPSP Draft EIR concluded all biological <br />resource impacts associated with EPSP development could be mitigated to less-than-significant <br /> <br />4 Government Code § 65583.2(b)(4)-(5) & (g)(1). <br />5 Government Code § 65583.2(b)(5)(B). <br />6 See Chapter 8, East Pleasanton Specific Plan, Revision 1 (November 2014). <br />7 See Government Code § 65583.2(b)(4); State Department of Housing and Community Development, Housing <br />Element Site Inventory Guidebook (June 10, 2020), p. 10 (housing element analysis must demonstrate that <br />environmental constraints will not preclude development on sites in the inventory). <br />8 EPSP Draft EIR, Ex. 3.3-3; East Pleasanton Specific Plan, Revision 1, Figure 5.2 (showing proposed parks and open <br />space within the EPSP). <br />9 Id.