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Finding/
<br />Comment #Comment Response Reference
<br />City of Pleasanton 6th Cycle Housing Element
<br />HCD November 14, 2022 Letter - Comments and Responses - December 2, 2022
<br />Attachment 1, Exhibit A
<br />B.2
<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).)
<br />Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families;
<br />farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd.
<br />(a)(7).)
<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://www.hcd.ca.gov/community-
<br />development/building-blocks/housing-needs/extremely-low-income-housing-needs.shtml.
<br />A subsection on extremely low-income households
<br />will be added to the housing needs assessment
<br />(Appendix A). This will summarize data, resources,
<br />and strategies currently dispersed throughout the
<br />draft Housing Element.
<br />Appendix A (Housing Needs Assessment),
<br />Section A.3.4 (Special Housing Needs)
<br />B.2 (cont)
<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 />analyze the number of lower-income households overpaying for housing by tenure (i.e., renter and owner) and add or modify policies and
<br />programs as appropriate.
<br />Additional detail on overpayment data will be
<br />added with reference to relevant programs.
<br />Appendix A (Housing Needs Assessment),
<br />Section A.5.3 (Overpayment)
<br />B.2 (cont)
<br />Special Housing Needs: While the element reports data on households and persons with special housing needs, the element must also
<br />describe the resources available and effectiveness of strategies to these special housing needs groups, then determine the magnitude of
<br />housing needs to better formulate policies and programs.
<br />Resources available to special needs populations
<br />and effectiveness of strategies will be added. Also,
<br />see Finding/Comment A.
<br />Appendix A (Housing Needs Assessment),
<br />Section A.3.4 (Special Housing Needs)
<br />B.3
<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
<br />analysis shall consider factors including the extent to which existing uses may constitute an impediment to additional residential
<br />development, the City’s past experience with converting existing uses to higher density residential development, the current market demand
<br />for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of
<br />the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to
<br />encourage additional residential development on these sites. For example, the element lists various factors (e.g., age of structure,
<br />development capacity through density and FAR) utilized to indicate the potential for redevelopment in the planning period; 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 Tri-Valley)
<br />and list the values of the factors for prior uses.
<br />Data on existing/previous uses and other
<br />information (e.g., building age) will be added to the
<br />pipeline project table (Table B-3) if available.
<br />Similar data will be added to nonvacant sites
<br />development Table B-9 as available. Discussion
<br />will be expanded to reflect this data.
<br />Appendix B (Sites Inventory &
<br />Methodology), Section B.2.2 (Entitled and
<br />Proposed Developments) and Section
<br />B.2.5 (Suitability of Nonvacant Sites)
<br />B.3 (cont)
<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 />impediment to additional residential development and will likely discontinue in the planning period. Absent findings (e.g., adoption resolution)
<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 />The required finding will be included in the
<br />resolution adopting the Housing Element.N/A
<br />B.3 (cont)Finally, the housing element must include a program to provide replacement housing. (Gov. Code, § 65583.2, subd. (g)(3).) The replacement
<br />housing program must adhere to the same requirements as set forth in Government Code section 65915, subdivision (c), paragraph (3).
<br />A new program will be added that reflects state law
<br />requirements for replacement of protected housing
<br />units.
<br />New program under Goal 3 (Conserve and
<br />improve the existing housing stock).
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