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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
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