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