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Pleasanton City Council <br /> BRAUN <br /> + <br /> (P A <br /> RAUNMARTELILP <br /> January 18, 2023 <br /> Page 10 <br /> City Council and Planning Commission would use every tool available to stop them.1° There is <br /> no reference to owner interest in building housing here, even though the commercial zoning <br /> district might in theory permit residential uses. Nor is there any realistic expectation that the <br /> narrower portion at the back of the parcel—another mid-block right of way through to Railroad <br /> Avenue—could realistically provide the claimed 25 units/acre. Absent evidence and a proper <br /> finding by the City Council that the existing use is likely to discontinue during the next eight <br /> years,the site is not appropriately listed as accommodating 18 units of lower income housing. <br /> 8. Pimlico Area (Hertz and Avis)(APN 946-1101-31-2, -35-02, and -36-04) <br /> Prior to the Planning Commission meeting on January 12, 2023,these three parcels <br /> between Pimlico Drive and Highway 580 had been removed from the inventory as lacking <br /> sufficient evidence that it would realistically develop during the next eight years. But after a <br /> Planning Commissioner claimed at the January 2023 Planning Commission meeting to have <br /> talked to two out of the three owners, and said they were interested in potential redevelopment <br /> (though he didn't identify what they said,or most importantly,when they would consider <br /> building something),the Planning Commission voted to recommend that the City Council re- <br /> include this site on the inventory, subject to further work by the staff. <br /> Because of the compressed timeframe and the last-minute re-addition, it isn't clear <br /> whether this site will or won't be included in the inventory, or what evidence exists to show that <br /> it likely to develop. Given the approach about other sites, however, we note the following. First, <br /> there are three owners, and the City should not include all three parcels unless each of them <br /> express interest in redeveloping during the next eight years in writing. See HCD Site Inventory <br /> Guidebook(identifying HCD's interpretation of"substantial evidence"). Second,there are <br /> existing tenants, including Hertz and Avis. There may be long-term leases that will maintain <br /> their existing uses sufficiently into the housing cycle to preclude redevelopment during the next <br /> eight years. Absent a finding based on substantial evidence that the existing uses are likely to <br /> discontinue—and currently,the draft contains nothing, because this site had been dropped off <br /> entirely—this site is not appropriately counted as accommodating lower income housing. <br /> 9. Valley Plaza(APNs 946-3295-6, -7, -9, -10, -11, -12, -13, and -3295-2-2). <br /> The Valley Plaza site(area 18) is a 7.81-acre commercial center with multiple buildings <br /> and associated surface parking on seven parcels. Some of the owners are interested in high <br /> density residential development of a portion of the site, but unfortunately has run into substantial <br /> resistance from the community,the Planning Commission, and members of the City Council, and <br /> so have scaled back their plans. As of the January 3, 2023 draft,the site was counted as meeting <br /> 166 units of the RHNA need: 90 lower income, 55 moderate, and 21 above moderate. <br /> 10 If the City Council doubts this, it is urged to consider the reaction to building residential <br /> housing on the considerably less picturesque Valley Plaza, discussed further below. <br />