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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.4 (cont)
<br />In addition, the element concludes development standards are not an impediment to residential development as the use of the Planned Unit
<br />Development (PUD) process allows for standards to be created on a case-by-case basis. However, the element should address
<br />development standards, specifically parking, use of mid-point density, and heights, for impacts on cost, supply, housing choice, approval and
<br />project certainty, and financial feasibility, and include programs to address identified constraints.
<br />Parking analysis will be expanded and a new
<br />program added to establish lower multi-family
<br />parking rates for studio and one-bedroom units
<br />and not require covered parking for studio and one-
<br />bedroom units.
<br />PUD discussion will be expanded and program
<br />added for a modified PUD process for rezone sites
<br />that is a conformance review (applies only
<br />objective standards and does not require Council
<br />approval).
<br />Appendix C (Housing Constraints), Section
<br />C.2.2 (Land Use Controls) - Development
<br />Standards
<br />B.4 (cont)
<br />Fees and Exaction: While the element describes required fees for single family and multifamily housing development, it must also analyze
<br />their impact as potential constraints on housing supply, cost and feasibility. For example, the element (p. C-35) concludes that fees account
<br />for a portion of total development costs for a multifamily project but should also evaluate the impacts to support this conclusion, including the
<br />impact of fees individually and cumulatively. Excessive fees for housing developments have significant impacts on housing cost, feasibility
<br />and production; especially when considering various housing types. The element should include an evaluation of these fees and add
<br />programs to address this constraint.
<br />Fee analysis conclusion will discuss City impact
<br />fees as being lower or comparable to neighboring
<br />jurisdictions. Program 2.3 will be revised to commit
<br />to revising fees to a per square foot basis where
<br />feasible.
<br />Appendix C (Housing Constraints), Section
<br />C.2.4 (Permits and Procedures) - Fee
<br />Analysis; Program 2.3
<br />B.4 (cont)
<br />Local Processing and Permit Procedures: The element generally describes the Planned Unit Development (PUD) process but must analyze
<br />this process for impacts on supply, cost, financial feasibility, timing and approval certainty. For example, the analysis should clearly state
<br />whether the Planned Development process is mandatory or optional, whether the burden of establishing zoning and development standards
<br />typically rests with the City or developers, particularly on identified sites, any absence of fixed development standards, any additional
<br />legislative approvals and any other requirements or mechanisms that may act as a constraint. While the element’s Program 6.1 commits to
<br />adopting objective design and development standards, the element should describe how this process is currently implemented, the effect on
<br />approval timelines, and the effect on approval certainty.
<br />Planned Unit Development discussion will be
<br />expanded to describe when PUDs are mandatory
<br />(e.g., mixed-use sites), how PUD standards are
<br />established (developer proposed vs. City initiated),
<br />and how a modified PUD process will be
<br />established for rezone sites (new program).
<br />Appendix C (Housing Constraints), Section
<br />C.2.4 (Permits and Procedures) - Planned
<br />Unit Development
<br />B.4 (cont)
<br />On/Off-Site Improvements: While the element identifies some improvement requirements, such as minimum street widths the element must
<br />also analyze their impact as potential constraints on housing supply and affordability. For additional information and a sample analysis, see
<br />the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/constraints/codes-and-enforcement-on-offsite-
<br />improvement-standards.shtml.
<br />Analysis will be expanded to discuss infill (e.g.,
<br />downtown) vs. more peripheral areas, reference
<br />Capital Improvement Program, and discuss traffic
<br />thresholds (i.e., LOS).
<br />Appendix C (Housing Constraints), Section
<br />C.2.5 (On and Off-site Improvements)
<br />Constraints on Housing for Persons with Disabilities: The element must evaluate constraints on housing for persons with disabilities, as
<br />follows:
<br />Reasonable Accommodation : The element indicates a reasonable accommodation request must not fundamentally require an alteration to
<br />City programs or laws, including but not limited to land use and zoning, and findings related to impacts on surrounding uses. However,
<br />reasonable accommodation is intended as an exception process to zoning, development standards and any other land use controls to
<br />provide access to housing for persons with disabilities. The element must include a program to amend the reasonable accommodation
<br />process and remove constraints to establish an appropriate process.
<br />The reasonable accommodations analysis will be
<br />revised to identify two findings related to
<br />fundamental alteration of City law and impacts on
<br />surrounding uses as constraints (Municipal Code
<br />18.86.060.A.4 and 5). A new program will be
<br />added to amend these findings to clarify intent
<br />while ensuring public health and safety objectives
<br />are maintained.
<br />Appendix C (Housing Constraints), Section
<br />C.2.2 (Land Use Controls) - Reasonable
<br />Accommodation
<br />Definition of Family : The element should fully describe and evaluate the definition of family for potential constraints on housing for persons
<br />with disabilities.
<br />The analysis of the definition of family will be
<br />expanded, and Program 5.6 will be revised to
<br />include amending the Zoning Ordinance definition
<br />of family to remove any relation by blood or
<br />marriage.
<br />Appendix C (Housing Constraints), Section
<br />C.2.2 (Land Use Controls) - Housing for
<br />Persons with Disabilities; Program 5.6
<br />B.4 (cont)
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