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• <br /> Meghan Campbell (I FARELLA <br /> BRAUN+MARTELup <br /> November 30, 2022 <br /> Page 9 <br /> Subtract: <br /> 1. BART parking lot 555 <br /> 2. Kaiser parking lot 182 <br /> 3a. Stoneridge 941120109403 (table B-12) 88 <br /> 3b. Stoneridge 941-120109403 (table B-13) 141 <br /> 3c. Stoneridge(new sites, e.g., Macy's) 532 <br /> 4. 3657-3675 Old Santa Rita Road 79 <br /> 5. 3400-3500 Boulder Court 284 <br /> 6. Rose Pavilion shopping center 62 <br /> Total after excluding invalid sites: 2,190 <br /> RHNA need for very low/low income housing in 2023- <br /> 2031 (after subtracting ADUs/Approved Projects): <br /> 2,758 <br /> Shortfall: 568 <br /> Based on the analysis above, Pleasanton's draft Housing Element does not comply with <br /> state law, because it proposes to meet more than 50%of the need for affordable housing with <br /> sites that are not vacant, and does so without substantial evidence that they are likely to be <br /> redeveloped. The City's current analysis, stating that it lacks information about whether there <br /> are leases (rather than investigating and determining whether existing leases present an obstacle), <br /> failing to take into account whether buildings are newly remodeled, and failing to evaluate other <br /> obstacles to development in the next eight years, is insufficient to meet Pleasanton's <br /> responsibility under state housing law. <br /> Given the substantial need for suitable, available, and realistic housing sites zoned to <br /> meet Pleasanton's share of the regional need, additional sites will need to be identified and <br /> rezoned to ensure compliance with state housing law. <br /> Very truly yours, <br /> 2 Thomas B. Mayhe <br /> 36615\15167650.1 <br />