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