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P23-0480 & Tract 8680, 3300 Busch Road Planning Commission 27 of 29 Pursuant to State law (Government Code 65863), the City must always maintain an adequate inventory of sites able to meet its assigned Regional Housing Needs Allocation (RHNA), at each specified affordability level. The proposed project would include 311 above-moderate units, 62 Junior ADUs (which are assigned to various income categories based on allowable assumptions per HCD), and 101 lower-income units. The 6th Cycle Housing Element assumed Site 21 would yield up to 150 lower-income units and 490 above-moderate income units. Table 2 compares the assumed vs. proposed unit counts. As shown, the project would have a shortfall of 12 lower-income units and 173 above-moderate income units; and a surplus of 19 moderate-income units compared to what was projected in the Housing Element for this site . Table 2: No Net Loss Analysis 6th Cycle Assumed Units Project Proposed Difference Primary Units JADUs Lower-Income 150 101 37 -12 Moderate-Income 0 0 19 +19 Above Moderate-Income 490 311 6 -173 However, despite this deviation from the assumed unit count in the Housing Element, there would still be adequate remaining zoning capacity to absorb the shortfall and retain an adequate inventory of sites. The Housing Element inventory included a surplus or “buffer” of zoning capacity more than the RHNA across all categories. Even considering recently approved projects, and the Kiewit project, an adequate buffer would remain. There remains a buffer of 314 Above-Moderate units; 301 Lower-Income units; and 70 Moderate-Income units in the City’s housing sites inventory, and the approval would not require any future rezoning of additional sites to meet the City’s RHNA. Vesting Tentative Subdivision Map 8680 VTM 8680 shows a total of 351 lots, which comprises the various residential lots, park, Parcels A-F for open space, bioswales, etc., and 33 alleys as Reciprocal Access Easement (RAE). Parcels A-F and RAEs are to be privately owned and maintained by the Homeowners Association. A recent discussion with the project civil engineer indicates RAEs, instead of independent parcels owned and maintained by HOA, RAEs may become part of the lots whose owners share the maintenance responsibilities. If this is the case, the CC&Rs for single-family residential homes will reflect these amended obligations. ALTERNATIVES As outlined in the above analysis, staff finds the project, as proposed and conditioned, would minimize adverse impacts to the neighborhood and c onforms to the City’s requirements, and therefore, recommends the Planning Commission approve the project. However, alternatives to the proposal that could be considered by the Planning Commission include: 1. Deny the project; or 2. Approve the proposal with modifications to the site layout, building designs, uses, etc. PUBLIC NOTICE / PUBLIC COMMENT Notice of the application was sent to the surrounding property owners and tenants within a 1,000-foot radius of the site. Staff has provided the location and notification map as Exhibit G