An update on progress to meet Pleasanton's housing obligations and considerations for planning will be heard at the Pleasanton City Council's online meeting on Tuesday night, starting 7 p.m.
City staff will give an overview that evening of the sixth cycle Regional Housing Needs Allocation (RHNA) process and Housing Element process, as well as an early look at the city's potential RHNA allocation.
In June, the sixth cycle Regional Housing Need Determination (RHND) was issued to the Association of Bay Area Governments/Metropolitan Transportation Commission (ABAG/MTC). RHND reflects the total allocation of projected housing needed for the 2023-35 period for the entire nine-county Bay Area region, which is "approximately 2.35 times more units than were included in the prior cycle."
The draft local RHNA for each jurisdiction will be published in spring 2021 and finalized that summer. After receiving the final RHNA, each local jurisdiction will have until January 2023 to update the Housing Element for its General Plan, "including an action plan to adopt rezoning of adequate land to account for the assigned housing units."
The Housing Element is part of Pleasanton's General Plan, and outlines its current and future housing needs as well as proposed actions to meet them at all income levels. A housing element must meet "a series of very specific requirements" set by the state that relate to the scope, content and process by which it is updated and adopted, including review and certification by the state Department of Housing and Community Development (HCD).
The HCD requires each jurisdiction to "demonstrate capacity to meet and accommodate their local 'fair share' of the assigned Regional Housing Need Determination (RHND), including total housing units across a series of affordable categories."
Periodic preparation and updating is also required, ensuring the housing element reflects both the community's "unique concerns" and the state's housing goal of "attaining decent housing and a suitable living environment for every California family," according to staff.
The numbers haven't finalized yet but if Pleasanton's RHNA holds to that 2.3-fold increase, staff said "the city will need to plan for approximately 4,848 units for the 2023-35 period." The fifth and most previous RHNA cycle from 2015 to 2023 called for 2,067 housing units.
Last year, a 35-member Housing Methodology Committee (HMC) was formed, comprised of local officials and staff from each of the nine Bay Area counties as well as labor groups, environmental organizations, housing advocates and other stakeholders.
Pleasanton is participating on the HMC as one of two staff representatives for Alameda County (the other from Oakland), "providing an opportunity to closely monitor the RHNA methodology process, and weigh in on key decisions." The HMC is expected to make their recommendation to ABAG some time in September.
According to staff, "the HMC's initial recommendations have tended to skew larger RHNA allocations towards so-called 'high opportunity' and jobs-rich communities, including communities such as Pleasanton."
"Based on decision points made by the HMC to date, Pleasanton and neighboring Tri-Valley cities appear likely to receive an increased allocation that will be at least similar, proportionately, to the RHND increase, and potentially even larger," staff added.
However, the final allocation won't be set until next year, following extensive review and recommendation from the ABAG/MTC Executive Board and state approval.
The city will be required to include an updated inventory list of sites or parcels showing its "capacity to accommodate sufficient housing to meet the assigned RHNA goals."
Under current law, the jurisdiction is not required to build the RHNA-assigned housing units but instead adopt a land use program with "identification of specific sites with available infrastructure and suitable physical conditions to accommodate these housing units under market-driven conditions."
"It will be necessary for the city to identify and ultimately rezone a number of parcels," staff said. Like in previous years, staff said the "challenge and concern" is identifying higher-density sites for lower-income housing, and "it may also be necessary to identify sites, beyond those that are already zoned, to accommodate moderate and above-moderate units as well."
The city will also need to identify and ultimately rezone a number of parcels within its boundaries, including sites considered eligible to be "carried over" from prior inventory, assumed density and affordability levels for each site, and "potential constraints that might require adjustment to the capacity of certain sites, to a level that HCD would consider realistic."
Due to recent changes in state law, staff said the analysis and requirements for identifying sites is now more challenging and includes "an expansive list of criteria that must be used" to show HCD that sites -- especially non-vacant -- "are viable and suitable to be included in the inventory."
Another "key change" in state law is the requirement that previously identified Housing Element sites that remain undeveloped "to be modified to allow housing-by-right," and mandatory additional analysis for occupied high-density sites "to demonstrate that the existing uses would not impede additional residential development and that it is realistic to assume that the site will redevelop on the coming cycle." Staff added that "every effort will be made to utilize these sites if possible."
Based on a "very preliminary analysis," staff also estimated that "200 or more acres may need to be identified and/or rezoned for housing at various densities and affordability levels, this cycle," assuming about 1,000 units can be carried over from the previous cycle.
Though difficult to give an "exact comparison" between the current and prior cycle, the total inventory of all sites included about 594 acres, with 87 acres labeled as high density housing sites, yielding 1,711 total units.
Staff also highlighted the state's "no net loss" provision that requires a jurisdiction to find sites to accommodate its RHNA obligation if a project results in fewer units by income category. Per the last cycle, the city's inventory is "above that needed to meet the RHNA" -- an approach that staff said was "strategic" and meant to "provide a buffer in the event some sites did not remain viable."
Because most of the high density sites were counted as producing very-low and low-income units, if a similar approach is taken during the next cycle, staff said "it may be advisable to develop a secondary list of sites that would be eligible for rezoning if and when necessary, to meet no net loss requirements."
In this cycle, according to the staff report, it may also be beneficial to consider adding 10 more dwelling units per acre (DUA) at high-density sites, from 30 up to 40 DUA. The city could also consider "allocating a share of the moderate- and above-moderate need to higher density sites and in multi-family developments."
The city Planning Commission has been suggested to act as the advisory body for the plan, instead of forming a separate task force, and that community input be continually sought through public meetings and workshops, and regular council consultations.
To that end, staff recommended hiring an outside consultant for assistance, and plans to issue a Request for Proposals (RFP) for both planning and California Environmental Quality Act (CEQA) purposes. A lead consultant would be selected to prepare the Housing Element Update, and the professional services contract brought to the council for review and approval at a later date.
Staff also said they believe "it will still be possible to dovetail the key decision points" of the East Pleasanton Specific Plan with the Housing Element Update and sites inventory.
"The ability to process the two plans concurrently will allow for the City Council to take into account whatever increment of the RHNA may be solved in East Pleasanton and provide more certainty as it proceeds with the Housing Element update."
Because the city will be well underway with its Housing Element analysis before the draft East Side Specific Plan is finished, staff said the "information and outcomes from each process can be reflected in both documents, including the required CEQA analysis."