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Gerry Beaudin, City Manager <br />Page 2 <br /> <br /> <br />examining existing uses and potential for redevelopment, owner interest). To <br />utilize this approach, the element should be revised, as follows: <br /> <br />• Indicators of Potential: The element uses a tripling of existing versus <br />allowable units or floor area ratio (redevelopment ratio) and the age of <br />structures to indicate potential for redevelopment. Then, the element lists <br />recent examples but should also list recent examples by these indicators <br />to support their validity as found in the prior review. For example, the <br />element lists development in the Tri-Valley (Table B-10) but should also <br />list the prior uses by the redevelopment ratio and age of structure. Based <br />on this analysis, the element may need to adjust the indicators of potential <br />and modify the sites inventory. <br /> <br />• Site-by-Site Assessment: The element includes a site-by-site assessment <br />of the extent existing uses impede additional development and, in many <br />cases, the element demonstrates the potential for redevelopment. <br />However, in other cases, the element does not describe affirmative owner <br />interest or should further evaluate the extent existing uses impede <br />additional development. For example, in Areas 7 and 8, the element <br />describes the owner is interested in evaluating future development or <br />interested in rezoning. These are not affirmative statements of interest in <br />residential development in the planning period. The element should either <br />clarify interest or include additional analysis to demonstrate the potential <br />for redevelopment. Additional other cases include sites that are owned by <br />schools (Areas 25 and 27) or BART where the element should discuss <br />schedules for disposition or development. Finally, public comments have <br />pointed to various issues that may impact the potential for redevelopment <br />in the planning period. These comments should be addressed. The <br />inventory should be adjusted if necessary and programs (e.g., increasing <br />allowable densities) should be added or modified as appropriate. <br /> <br />In addition, for your information, the element relies on nonvacant sites to <br />accommodate 50 percent or more of the housing needs for lower-income <br />households, which triggers requirements to make findings based on substantial <br />evidence that the existing use is not an impediment and will likely discontinue in <br />the planning period. While the resolution of adoption includes findings, any <br />changes to the analysis should be reflected in future re-adoption of the element, <br />if necessary. <br /> <br />Environmental Constraints: The element explains there are no environmental <br />constraints to development on identified sites but should also describe any other <br />known constraints that preclude development in the planning period. Examples <br />include easements, property conditions, compatibility with other land use controls <br />and contamination or necessary site mitigations and timing impacts. <br />