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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 A1 <br />B.4 (cont) <br />Approval Time and Requests Lesser Densities: The element must include analysis of requests to develop housing at densities below those <br />identified, the length of time between receiving approval for a housing development and submittal of an application for building permits that <br />potentially. The element must address any hinderance on the development of housing and include programs as appropriate. <br />Discussion on projects coming in with lower <br />densities than allowed/projected will be expanded <br />with specific examples (Appendix B, Section B.2.3, <br />A subsection heading will be added for Length of <br />Time Between Approval and Building Permit <br />Application in Appendix C. <br />Appendix B (Sites Inventory & <br />Methodology), Section B.2.3 (Density and <br />Capacity Assumptions) - Realistic Capacity <br />and Development Trends; Appendix C <br />(Housing Constraints), Section C.2.4 <br />(Permits and Procedures) <br />C.1 <br />Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may <br />recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the <br />local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing <br />Element... (Gov. Code, § 65583, subd. (c).) <br />To have a beneficial impact in the planning period and address the goals of the housing element, programs must be revised with discrete <br />timelines (e.g., at least annually or by January 2025), including for Programs 1.5 (Assist in Development of Lower- and Extremely-Lower <br />Income Housing), 1.6 (High-Density Housing Outreach), 1.7 (Kiewit and Stoneridge Site Development), 2.1 (Inclusionary Zoning Ordinance), <br />2.2 (Lower-Income Housing Fees), 2.3 (Fees Nexus Study), 2.7 (Density Bonus Zoning Amendments), 2.8 (Rental Housing Assistance), 3.1 <br />(Manufactured Housing Zoning Amendment), 3.5 (Housing Rehabilitation), 4.4 (Housing Infrastructure), 5.1 (Regional Homeless <br />Coordination), 5.6 (Zoning Code Amendments), and 6.1 (Objective Design and Development Standards). <br />Discrete timing (month and year) will be added to <br />identified programs. Some program timelines will <br />be shifted earlier, as feasible, to result in larger <br />beneficial impact during the planning period. <br />Various programs. <br />C.1 (cont) <br />In addition, while Program 1.8 commits to monitoring Accessory Dwelling Unit (ADU) production halfway through the planning period, this <br />monitoring timeline should be adjusted to every two years and include alternative actions by a specified time (e.g., within six months) if ADUs <br />are not meeting assumptions in the sites inventory, including, but not limited to, additional rezoning. <br />Program 1.8 will be adjusted to have review and <br />revision action (if necessary) every two years. If <br />significant shortfall of ADU target occurs, a <br />rezoning action will be noted as potential action. <br />Program 1.8 <br />C.2 <br />Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and <br />with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that <br />could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and <br />to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the <br />development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, <br />housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. <br />Code, § 65583, subd. (c)(1).) <br />As noted in Finding B3, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not <br />established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a <br />shortfall of sites or zoning available to encourage a variety of housing types. <br />See responses under Comment B.3, above.N/A <br />C.2 (cont) <br />In addition, Program 5.6 (Zoning for Special Needs Housing) currently commits to allow transitional and supportive in all zones allowing <br />residential uses and not subject to any special requirements consistent with AB 2162. However, this program conflates two unique <br />requirements. First, the program must commit to permit transitional and supportive in all zones allowing residential then, second and <br />separately, the program should commit to permit permanent supportive housing without discretionary action pursuant to Government Code <br />section 65651. <br />Program 5.6 language will be revised so as to not <br />conflate distinct requirements for transitional and <br />supportive housing. <br /> Program 5.6 <br />C. Housing Programs <br />5