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Gerry Beaudin, City Manager <br />Page 4 <br /> <br /> <br />Local Processing and Permit Procedures: HCD’s prior review found the element <br />must analyze the Planned Unit Development (PUD) process for impacts on <br />supply, cost, financial feasibility, timing and approval certainty. In response, the <br />element now explains that the process is optional under certain circumstances, <br />sites will be rezoned with objective standards to mitigate the constraint and <br />Program 4.8 (Streamlined Review) is intended to further mitigate the constraint. <br />However, the process is required for mixed use sites and low or medium density <br />sites above the mid-point density – potentially a disproportionate impact on <br />higher density development. Also, an analysis of potential constraints on <br />development should not be limited to sites and accommodating the RHNA and <br />Program 4.8 lacks specifics in how the potential constraint will be addressed. As <br />a result, the element should specifically analyze impacts of the process on mixed <br />use and low or medium density sites above the mid-point density. The analysis <br />should address supply (number of units), cost, financial feasibility, timing and <br />approval certainty and Program 4.8 should be revised depending on the <br />outcomes of a complete analysis. <br /> <br />3. Promote and affirmatively further fair housing opportunities and promote housing <br />throughout the community or communities for all persons regardless of race, <br />religion, sex, marital status, ancestry, national origin, color, familial status, or <br />disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).) <br /> <br />While the element includes meaningful actions toward affirmatively furthering fair <br />housing (AFFH), these actions should add or increase numeric targets and <br />geographic targeting should be fine-tuned to better promote inclusive <br />neighborhoods. For numeric targets, the element should consider adding or <br />increasing targets for Programs 2.1 (Inclusionary), 2.4 (Local Funds), 2.9 (See <br />State and Federal Funds), 2.12 (Pleasanton Down Payment Assistance Loan <br />Program), 5.4 (Accessibility) and 5.5 (City's Lower Income Housing Fund). For <br />geographic targeting, the element should consider areas of relatively higher <br />income in addition to highest resource and concentrated areas of affluence. <br /> <br />In addition, promoting housing mobility removes barriers to higher opportunity <br />areas and strategically enhances access to housing choices and affordability to <br />promote more inclusive neighborhoods, cities and regions. Among other factors, <br />the City is predominantly a racially concentrated area of affluence, higher <br />resource and highest median incomes in contrast to the rest of the region. As a <br />result, the element should include a significant and robust suite of actions (not <br />limited to the RHNA) to promote housing mobility and increasing housing choices <br />and affordability throughout the City. The element includes some meaningful <br />actions such as Programs 1.5 (Extremely Low-income Households), 1.8 <br />(Accessory Dwelling Units), 2.1 (Inclusionary), 2.12 (Pleasanton Down Payment <br />Assistance Loan Program), 5.4 (Accessibility) and 5.5 (City's Lower Income <br />Housing Fund). However, the element should increase the objectives as noted <br />above and should include additional actions to promote more housing choices