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Gerry Beaudin, City Manager Page 3 Infrastructure: The element describes that identified sites have access to infrastructure and sufficient total sewer capacity is available or planned to accommodate the regional housing needs allocation (RHNA). However, the element should also clarify whether there is sufficient total (existing and planned) water capacity to accommodate the RHNA and modify Programs 4.4 (Infrastructure Deficiencies) and 4.5 (Water Supply) if necessary. Electronic Sites Inventory: Although the City has submitted electronic sites inventory as described in the prior review, if any changes occur, the City should submit revisions as part of any future re-adoption or submittal. Please see HCD's housing element webpage at https://www.hcd.ca.gov/planning-and-community- development/housing-elements for additional information. Programs: As noted above, the element does not include a complete site analysis. Depending upon the results of that analysis, the City may need to add or revise programs. In addition, the element should be revised, as follows: • Program 1.7 (Large Sites): While Program 1.7 commits to facilitate development, the Program should also be modified and geared toward promoting affordability for the lower-income RHNA as assumed in the inventory. For example, the program could address parceling at appropriate sizes and other site planning, additional incentives or other mechanism to encourage affordability, numerical objectives, including affordability, consistent with assumptions in the sites inventory and alternatives strategies to meet the lower-income RHNA should progress not be made, including, but not limited to, rezoning additional sites. • Program 1.10 (Annexations): The Program commits to complete annexations as well as alternative actions if annexations are not completed. However, the Program should also include steps and milestones the City will take toward annexation to better track progress and make adjustments as appropriate. 2. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).) Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities... (Gov. Code, § 65583, subd. (c)(3).)