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City of Pleasanton 6th Cycle Housing Element
<br /> HCD November 14,2022 Letter-Comments and Responses-DRAFT
<br /> December 2,2022
<br /> Comment - * Response Reference
<br /> Comment
<br /> Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and
<br /> projected needs for all income levels,including extremely low-income households(Gov.Code,§65583,subd.(a)(1).)
<br /> Include an analysis and documentation of household characteristics,including level of payment compared to ability to pay,housing
<br /> characteristics,including overcrowding,and housing stock condition (Gov.Code,§65583,subd(a)(2).) A subsection on extremely low-income households
<br /> will be added to the housing needs assessment
<br /> Analyze any special housing needs such as elderly,persons with disabilities,including a developmental disability,large families, (Appendix A) This will summarize data,resources,Appendix A(Housing Needs Assessment),
<br /> B.2
<br /> farmworkers;families with female heads of households;and families and persons in need of emergency shelter.(Gov.Code,§65583,subd. and strategies currently dispersed throughout the Section A.3.4(Special Housing Needs)
<br /> (a)(7).) draft Housing Element.
<br /> Extremely Low-Income(ELI)Households.While the element quantifies existing and projected ELI households,it must also analyze their
<br /> housing needs The analysis of ELI housing needs could consider tenure,overpayment,resources and the effectiveness of strategies and
<br /> the magnitude of housing need To assist the analysis,see the enclosed data and sample analysis at http://wvniv hcd.ca goy/community-
<br /> developmentibuilding-blocks/housing-needs/extremely-low-income-housing-needs.shtml.
<br /> Overpayment.While the element identifies the total number of households overpaying for housing(pp.A-59 to A-67),it must quantify and
<br /> Additional detail on overpayment data will be Appendix A(Housing Needs Assessment),
<br /> 8.2(cont) analyze the number of lower-income households overpaying for housing by tenure(i e.,renter and owner)and add or modify policies and
<br /> added with reference to relevant programs Section A.5.3(Overpayment)
<br /> programs as appropriate
<br /> Special Housing Needs While the element reports data on households and persons with special housing needs,the element must also Resources available to special needs populations
<br /> Appendix A(Housing Needs Assessment)
<br /> 8.2(cont) describe the resources available and effectiveness of strategies to these special housing needs groups,then determine the magnitude of and effectiveness of strategies will be added.Also,
<br /> Section A 3 4(Special Housing Needs)
<br /> housing needs to better formulate policies and programs. see Finding/Comment A.
<br /> An inventory of land suitable and available for residential development,including vacant sites and sites having realistic and demonstrated
<br /> potential for redevelopment during the planning period to meet the locality's housing need for a designated income level,and an analysis of
<br /> the relationship of zoning and public facilities and services to these sites.(Gov.Code,§65583,subd.(a)(3))
<br /> Suitability of Nonvacant Sites The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites.The Data on existing/previous uses and other
<br /> analysis shall consider factors including the extent to which existing uses may constitute an impediment to additional residential information(e g,building age)will be added to the Appendix B(Sites Inventory&
<br /> development,the City's past experience with converting existing uses to higher density residential development,the current market demand pipeline project table(Table B-3)if available Methodology),Section B 2 2(Entitled and
<br /> 8.3
<br /> for the existing use,an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of Similar data will be added to nonvacant sites Proposed Developments)and Section
<br /> the site for additional residential development,development trends,market conditions,and regulatory or other incentives or standards to development Table B-9 as available Discussion 8.2 5(Suitability of Nonvacant Sites)
<br /> encourage additional residential development on these sites For example,the element lists various factors(e g,age of structure, will be expanded to reflect this data.
<br /> development capacity through density and FAR)utilized to indicate the potential for redevelopment in the planning penod;however,it should
<br /> support the validity of these factors.To support these factors,the element should evaluate development trends or recent experience in
<br /> redevelopment relative to the factors For example,the element could utilize Table B-9(Development on Nonvacant Sites in the Tn-Valley)
<br /> and list the values of the factors for prior uses.
<br /> In addition,specific analysis and actions are necessary if the housing element relies upon nonvacant sites to accommodate more than 50
<br /> percent of the RHNA for lower-income households For your information,the housing element must demonstrate existing uses are not an
<br /> The required finding will be included in the
<br /> B 3(cent) impediment to additional residential development and will likely discontinue in the planning period Absent findings(e.g.,adoption resolution) N/A
<br /> resolution adopting the Housing Element.
<br /> based on substantial evidence,the existing uses will be presumed to impede additional residential development and will not be utilized
<br /> toward demonstrating adequate sites to accommodate the RHNA
<br /> Finally,the housing element must include a program to provide replacement housing.(Gov.Code,§655832,subd.(g))3>)The replacement A new program will be added that reflects state law New program under Goal 3(Conserve and
<br /> B 3(cant) requirements for replacement of protected housing
<br /> housing program must adhere to the same requirements as set forth in Govemment Code section 65915,subdivision(c),paragraph(3). units. improve the existing housing stock).
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