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As seen in Figure 2 below from Appendix B, this estimated capacity reflects a shortfall when compared to the total RHNA allocation (total of 5,965 units). Thus, a total of up to 25 additional sites have been identified which may be considered for future re-zoning to allow housing, to provide adequate sites capacity to meet the RHNA. Currently, the sites inventory includes a surplus of units above the required RHNA, particularly in the very-low/low-income category (generally derived from sites identified for density above 30 dwelling units/acre), and a smaller surplus of moderate- and above-moderate units. Staff notes that the distribution of units across income categories varies somewhat from the estimates provided in earlier stages of the process, which was much more preliminary in nature. Many of those changes resulted in shifting projected unit capacity from the lower-income category, to either moderate or above-moderate — primarily based on screening sites through the detailed criteria set forth by HCD for sites considered suitable to accommodate lower-income housing (such as site size). Fi•ure 2: A• •endix B, Table B-11, Residential Develo•ment Potential and RHNA Extremely Very Low Moderate Above Total Low Low Moderate RHNA See Very Low 1,750 1,008 894 2,313 5,965 ADUs See Very Low 5 28 46 14 93 Approved/Entitled Projects - - 23 - 393 416 Remaining RHNA See Very Low 1,745 957 848 1,906 5,456 Site Inventory See Very 1,090 552 641 2,283 Low/Low Surplus/(Shortfall) See Very (1,612) (296) (1,265) (3,173) Low/Low Rezone Sites(Net New) See Very 2,814 454 1,421 4,689 Low/Low Surplus/(Shortfall)With See Very 1,202 158 156 1,516 Rezone Sites Low/Low Source: City of Pleasanton, LWC This approach in the current draft was discussed by City Council to allow the City to account for outcomes of other review and analysis that is still pending, including the CEQA analysis, review by HCD, and additional public input; it will allow the greatest flexibility after HCD's initial review. The adequacy of the sites inventory will be evaluated by HCD and this input may result in removal of some sites, reduced favorability of certain sites, and/or suggested modifications of capacity and affordability assumptions. In any case, during the final phases of Housing Element review that will take place at the end of this year, the City Council will have more complete information to potentially further narrow the sites list and provide a unit count that is closer to the needed RHNA number. With respect to above-moderate capacity, staff notes that provisions of Housing Element law for sites subject to annexation (i.e., the Lester and Merritt sites) will require the City and Alameda County to negotiate the transfer of a portion of Alameda County's RHNA to the City, to account for incorporation of those parcels into the City of Pleasanton. This negotiation would occur following a future annexation — and while it is Page 9 of 18