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FA R E L L A THOMAS B.MAYHEW CHARLES J.HIGLEY BRAUN + MARTEL [LI' January 18, 2023 Via E-Mail City Council City of Pleasanton P.O. Box 520 Pleasanton CA 94566 Email: citycouncil(&,cityofpleasantonca.gov Re: Draft Housing Element for City of Pleasanton 2023-2031 Second Set of Comments of Housing Action Coalition Dear Mayor, Vice Mayor, and City Council Members: On behalf of the Housing Action Coalition,' we write to explain why you should not adopt the findings and draft site inventory proposed by staff for the 2023-2031 Housing Element for the City of Pleasanton. Most of the sites on the inventory designated for lower income housing are currently being used for other purposes. While some of them have an expressed owner interest in redevelopment, others do not, and the evidence is inconsistent with a desire to discontinue the existing use during the next eight years. This means that they are not realistic or available to meet the need for housing. The City is required to specify the development potential by considering"the extent to which existing uses may constitute an impediment to additional residential development,""the current market demand for the existing use,""an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development,"and other factors. Government Code § 65583.2(g)(1). For those sites listed as accommodating the lower income share of the need,the test further prohibits listing the sites unless the City Council makes specific findings based on evidence: "An existing use shall be presumed to impede additional residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period." Government Code § 65583.2(g)(2). The Housing Action Coalition is a nonprofit that advocates for building more homes at all levels of affordability to alleviate the Bay Area and California's housing shortage, displacement, and affordability crisis.