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ATTACHMENT 7 <br /> FA R E L L A TH°".�s B."�' \\ <br /> BRAUN + MARTELII <br /> November 30,2022 <br /> Via E-Mail <br /> Meghan Campbell <br /> Associate Planner <br /> E-Mail: mcampbell@cityofpleasantonca.gov <br /> Re: Draft Housing Element for City of Pleasanton 2023-2031 <br /> Comments of Housing Action Coalition <br /> Dear Ms. Campbell: <br /> On behalf of the Housing Action Coalition,' we write to comment on the draft 2023-2031 <br /> Housing Element for the City of Pleasanton. <br /> The draft Housing Element does not meet the City's obligation to plan and provide for <br /> affordable housing. Absent substantial revisions, it may be found in violation of state law. <br /> A. The City Includes Sites That Are Not"Suitable and Available,"Even <br /> Though They Do Not Have A"Realistic And Demonstrated Potential" For <br /> Redevelopment During The Planning Period To Meet The Need For <br /> Housing. <br /> One of the most concrete aspects of any housing element is the inventory of land <br /> "suitable and available"for residential development to meet the city's regional housing need by <br /> income level. Government Code § 65583(a)(3); HCD Housing Element Site Inventory <br /> Guidebook at p. 1. HAC Appendix Tab 1. The list is a specific means of evaluating whether the <br /> City has adequately planned for development of housing for all income levels. Where nonvacant <br /> sites are listed, there must be a"realistic and demonstrated potential for redevelopment"during <br /> the next eight years. Government Code § 65583(a)(3). <br /> To address past abuses—cities listing unrealistic sites—the California Legislature created <br /> a high standard for listing nonvacant sites,particularly where a city claims that the site is suitable <br /> and available for redevelopment as housing affordable to those with below average incomes. <br /> Where nonvacant sites are used to address over 50%of the need for affordable housing for those <br /> The Housing Action Coalition is a nonprofit that advocates for building more homes at <br /> all levels of affordability to alleviate the Bay Area and California's housing shortage, <br /> displacement,and affordability crisis. <br /> SAN FRANCISCO ST. HELENA www fbm corn <br />