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Pleasanton City Council BRAUN+A January 18, 2023 RAUNMARTELtLP Page 12 As for the four parcels that the owners wanted to develop with high-density housing and which the City lists as meeting the lower-income need, the future is uncertain. The Planning Commission has recommended reducing the number of units that could be built per acre. The owner may decide that this is not enough to create an economically viable project, particularly given the community opposition to any housing, and given that the buildings on the site have income-producing tenants. An owner's interest in building a high-density, mixed-use project is no assurance that the owner will remain interested in building a medium-density, mixed-use project. If the City Council follows the Planning Commission's recommendation to reduce the density,the City Council will lack the required evidence that the four parcels for lower-income housing (APNs 946-3295-6, -7, -10, and -3295-2-2)will"likely"cease their existing use as a retail center. At a minimum,the City Council should reject the Planning Commission's proposal to reduce the density of these parcels, and assure that the owner can build a project with high enough density to at least theoretically address the need for lower-income housing. 10. Metro 580 (APN 941-2779-9) Metro 580 is a shopping center next to the busy Interstate 580 freeway. The City proposes to rezone five acres of the 15.51 acre parcel for high density housing, and after the Planning Commission meeting, increased the proposed minimum density to 50 units/acre in order to take credit for accommodating 250 units of lower income housing. The City does not evaluate whether any site constraints would preclude development at the minimum density. In particular, we note the shape of the site and the proximity to the freeway. The site pinches down in the northeastern corner, ultimately to a narrow strip approximately 10 feet wide, running parallel to a drainage ditch for the interstate. The City does not appear to have evaluated, as required by Government Code section 65583.2(c),whether site conditions would preclude full development of the entire acreage, particularly after accounting for required setbacks. No one builds an apartment building that is only ten feet wide and forty feet tall. Evaluating the actual buildable acreage at the site should lead to a reduction in the number of units claimed, by assuring that the site is considered only for its realistic capacity. * * * The draft 2023-2031 Housing Element for Pleasanton does not comply with state law. The City Council cannot credibly claim to have"substantial evidence"that BART will build housing on its parking lot during the next eight years, that Kaiser will require all of its doctors and patients to walk or take transit to its Pleasanton medical center,that the Sunshine Saloon at Valley Plaza will become housing,that Metro 580 will develop apartments that fit on a 10-foot strip of property next to the freeway,that the Macy's Furniture Store at Rose Pavilion will be torn down to build housing,that the mysterious building at 120 Ray Street(which is probably a phone company utility connection site)will stop being used,that the hardware store no longer needs its parking lot, or even that the remaining four acres that Simon chose not to propose to build housing on at Stoneridge, rezoned over eleven years ago, will be developed as high-density housing during the next eight years. These sites are not underutilized: they contain active uses that are likely to continue.