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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.3 (cont) <br />Large Sites: While the element states large sites will only use ten acres of buildable acreage to accommodate lower-income RHNA, it must <br />still provide analysis regarding the development of housing for lower-income households on large sites where the acreage of the parcel <br />exceeds ten acres. Absent sufficient evidence that sites of equivalent size with affordability were successfully developed during the planning <br />prior planning period or other evidence that demonstrates the suitability of these sites, the large sites are deemed inadequate to <br />accommodate housing for lower-income households. For example, the element should describe the characteristics of anticipated <br />development on identified large sites, including opportunities and timing for specific-plan development, further subdivision, parceling, site <br />planning or other methods to facilitate appropriately sized sites that encourage the development of housing affordable to lower-income <br />households. Based on the outcomes of this analysis, the element should add or modify programs. <br />A discussion of successful development of 5th <br />Cycle sites (Avalon Bay and Vintage) will be <br />discussed. Owner interest and proposed plans for <br />Hacienda Terrace site will be added to discussion. <br />Program 1.7 will be expanded to include outreach <br />efforts with other large site owners to facilitate <br />development (Hacienda Terrace, Metro 580, and <br />Oracle). <br />Appendix B (Sites Inventory & <br />Methodology), Section B.2.4 (Methodology) <br />- Phase 3: Categorization; Program 1.7 <br />B.3 (cont) <br />Environmental Constraints: While the element provides information on general environmental constraints, it should also relate those <br />constraints to identified sites, including a discussion of any other known conditions (e.g., shape, easements, contamination) and impacts on <br />development in the planning period. <br />Statements identifying that no environmental <br />constraints, contamination, easements, or parcel <br />shape would constrain housing will be added. <br />Information from the Draft EIR will be reference as <br />appropriate. Discussion will also note that <br />development capacities reflect conservative <br />estimates and site conditions (e.g., buildable area). <br />Appendix B (Sites Inventory & <br />Methodology), Section B.2.4 (Methodology) <br />- Phase 4: Site-by-Site Assessment <br />B.3 (cont) <br />Infrastructure: The element includes some discussion on water and sewer providers in the City (pp. C-41 to C-43). However, it must also <br />clarify whether sufficient total water and sewer capacity (existing and planned) can accommodate the regional housing need and include <br />programs if necessary. <br />Discussion will be expanded to describe that <br />sewer capacity is sufficient to accommodate <br />RHNA, but that water supply is a constraint <br />consistent with the Draft EIR. A program will be <br />added to identify that the City will implement a <br />solution to address water supply. <br />Appendix B (Sites Inventory & <br />Methodology), Section B.2.4 (Methodology) <br />- Phase 4: Site-by-Site Assessment; <br />Appendix C (Housing Constraints), Section <br />C.4.2 (Infrastructure Constraints) <br />B.3 (cont) <br />Electronic Sites Inventory: For your information, pursuant to Government Code section 65583.3, the City must submit an electronic sites <br />inventory with its adopted housing element. The City must utilize standards, forms, and definitions adopted by HCD. Please see HCD’s <br />housing element webpage at https://www.hcd.ca.gov/community-development/housing-element/index.shtml#element for a copy of the form <br />and instructions. The City can reach out to HCD at sitesinventory@hcd.ca.gov for technical assistance. <br />Form will be submitted with the adopted Housing <br />Element.N/A <br />B.3 (cont) <br />Zoning for a Variety of Housing Types (Emergency Shelters): Parking requirements for emergency shelters should only be the number of <br />spaces necessary for staff working in the shelter and no more than other uses in the same zones. The element indicates one space per four <br />shelter beds plus one parking space for each employee then concludes the standards is similar to hotel uses. However, a standard of one <br />space per four beds is more than what is necessary to accommodate staff. As a result, the element should add or modify programs to revise <br />parking requirements for emergency shelters in compliance with state law. <br />Analysis will be revised to describe that <br />emergency shelter parking requirement exceed <br />that allowed by state law. Program 5.6 will be <br />revised to include an amendment to emergency <br />shelter parking requirements consistent with state <br />law. <br />Appendix C (Housing Constraints), Section <br />C.2.2 (Land Use Controls) - Emergency <br />Shelters/Low Barrier Navigation Centers; <br />Program 5.6. <br />B.4 <br />An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income <br />levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis <br />pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions <br />required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).) <br />An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all <br />income levels, including… …requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of <br />Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an <br />application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in <br />accordance with Government Code section 65584... (Gov. Code, § 65583, subd. (a)(6).) <br />Land Use Controls: While the element describes development standards and some land use controls, it must also analyze those land use <br />controls for impacts on housing supply (number of units), costs, financial feasibility, timing, approval certainty and ability to achieve <br />maximum densities without exceptions (e.g., conditional use permits, variance, planned development). <br />Additional discussion of RM zones will be added. A <br />program will be added to conduct additional <br />analysis and testing of standards in the RM zones <br />and modify those standards to ensure maximum <br />density can be achieved in the RM zones without <br />exception (e.g., PUD). <br />Appendix C (Housing Constraints), Section <br />C.2.2 (Land Use Controls) - Development <br />Standards <br />3