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Page 8 of 12 <br />issues that could limit development potential in East Pleasanton. The Draft EIR prepared for <br />the Arroyo Lago project found that the project site is suitable for the proposed development <br />from a geotechnical standpoint, provided that various measures and recommendations would <br />be implemented. The EIR for the East Lakes project will be required to separately analyze <br />potential geotechnical impacts from proposed development and identify mitigation measures <br />as needed to reduce these impacts. Similarly, Phase 1 hazardous materials reports and any <br />relevant findings related to other regulatory agencies’ designation or monitoring of the site <br />would be further elaborated and subject to City review, to ensure the site is developable and <br />does not pose unacceptable adverse health risks. <br /> <br />Inclusionary Units <br />The City of Pleasanton Inclusionary Zoning Ordinance (IZO) in Municipal Code Chapter 17.44 <br />establishes affordable housing requirements for new residential development in Pleasanton. <br />Under the IZO, as amended in December 2024, residential development projects with 10 or <br />more units must provide at least 15 percent of the project’s units as affordable to lower-income <br />households (inclusionary units). IZO provisions most relevant to the East Lakes projects <br />include: <br />• Clustering Inclusionary Units: The IZO generally requires inclusionary units to be <br />dispersed throughout the project, with some provisions to allow for limited clustering of <br />those units (e.g., by attaching smaller duplex or apartment units). Clustering units into a <br />single area of the site is permitted in conjunction with a tax-credit financed project; other <br />unit types may be grouped into smaller clusters that are themselves distributed in the <br />project. The City Council may also allow further clustering as part of an Alternative <br />Compliance request/approval. It is noted that, on a practical level, an apartment project <br />will have minimum size (typically between 70-120 units) in order to be competitive for <br />tax-credit financing and feasible to construct. <br /> <br />• Tenure and Affordability: Generally, apartment units are expected to provide rental <br />housing; townhomes and clustered single family units will typically provide ownership <br />opportunities, since it can be challenging to manage distributed rental units. Per the <br />IZO, affordable rental units are to be deed-restricted at up to 50 or 60% AMI, and for- <br />sale units up to 120% AMI. <br /> <br />• On-site Preference: The IZO establishes a strong City preference for inclusionary units <br />to be constructed on-site and in conjunction with market rate units within the same <br />project. <br /> <br />• Alternative Means of Compliance: The IZO allows alternatives to on-site inclusionary <br />units with (from most to least preferred): 1) alternative configurations, unit types or <br />clustering of units on site; 2) constructing units off-site; 3) dedicating land for an <br />affordable housing project; and 4) paying the affordable housing fee. The City Council <br />may approve an alternative means of compliance only upon finding that it is not feasible <br />or desirable to accommodate the inclusionary units on-site or that special circumstances <br />justify payment of fees over provision of units. <br /> <br />• Affordable Housing Fee: To approve payment of the affordable housing fee in lieu of <br />on-site inclusionary units, the City Council must find that all other alternative compliance <br />means are infeasible, and that “greater benefit would accrue to the City with respect to <br />Page 331 of 348