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<br /> <br />City of Pleasanton’s 6th Cycle (2023-2031) Draft Housing Element Page 3 <br />November 14, 2022 <br />Suitability of Nonvacant Sites: The element must include an analysis demonstrating the <br />potential for redevelopment of nonvacant sites. The analysis shall consider factors <br />including the extent to which existing uses may constitute an impediment to additional <br />residential development, the City’s past experience with converting existing uses to <br />higher density residential development, the current market demand for the existing use, <br />an analysis of any existing leases or other contracts that would perpetuate the existing <br />use or prevent redevelopment of the site for additional residential development, <br />development trends, market conditions, and regulatory or other incentives or standards <br />to encourage additional residential development on these sites. For example, the <br />element lists various factors (e.g., age of structure, development capacity through <br />density and FAR) utilized to indicate the potential for redevelopment in the planning <br />period; however, it should support the validity of these factors. To support these factors, <br />the element should evaluate development trends or recent experience in redevelopment <br />relative to the factors. For example, the element could utilize Table B-9 (Development <br />on Nonvacant Sites in the Tri-Valley) and list the values of the factors for prior uses. <br /> <br />In addition, specific analysis and actions are necessary if the housing element relies <br />upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower- <br />income households. For your information, the housing element must demonstrate <br />existing uses are not an impediment to additional residential development and will likely <br />discontinue in the planning period. Absent findings (e.g., adoption resolution) based on <br />substantial evidence, the existing uses will be presumed to impede additional residential <br />development and will not be utilized toward demonstrating adequate sites to <br />accommodate the RHNA. <br /> <br />Finally, the housing element must include a program to provide replacement housing. <br />(Gov. Code, § 65583.2, subd. (g)(3).) The replacement housing program must adhere to <br />the same requirements as set forth in Government Code section 65915, subdivision (c), <br />paragraph (3). <br /> <br />Large Sites: While the element states large sites will only use ten acres of buildable <br />acreage to accommodate lower-income RHNA, it must still provide analysis regarding <br />the development of housing for lower-income households on large sites where the <br />acreage of the parcel exceeds ten acres. Absent sufficient evidence that sites of <br />equivalent size with affordability were successfully developed during the planning prior <br />planning period or other evidence that demonstrates the suitability of these sites, the <br />large sites are deemed inadequate to accommodate housing for lower-income <br />households. For example, the element should describe the characteristics of anticipated <br />development on identified large sites, including opportunities and timing for specific-plan <br />development, further subdivision, parceling, site planning or other methods to facilitate <br />appropriately sized sites that encourage the development of housing affordable to <br />lower-income households. Based on the outcomes of this analysis, the element should <br />add or modify programs. <br /> <br />Environmental Constraints: While the element provides information on general <br />environmental constraints, it should also relate those constraints to identified sites, <br />including a discussion of any other known conditions (e.g., shape, easements, <br />contamination) and impacts on development in the planning period.