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<br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> Nov 12, 2025 <br /> <br />City of Pleasanton <br />P.O. Box 520 <br />Pleasanton, CA 94566 <br /> <br />Re: Proposed Housing Development Project at 4400 Black Avenue <br /> <br />By email: dmora@cityofpleasantonca.gov <br /> <br />CC: eluchini@cityofpleasantonca.gov; dsodergren@cityofpleasantonca.gov; <br />Pleasantoncityclerk@cityofpleasantonca.gov; gbeaudin@cityofpleasantonca.gov; <br />eclark@cityofpleasantonca.gov; <br /> <br />Dear Pleasanton Planning Commission, <br /> <br />The California Housing Defense Fund (“CalHDF”) submits this letter to remind the City of its <br />obligation to abide by all relevant state laws when evaluating the proposed 66-unit housing <br />development project at 4400 Black Avenue, which includes 7 low-income units and 2 very <br />low-income units. These laws include the Housing Accountability Act (“HAA”), the Density <br />Bonus Law (“DBL”), AB 130 and California Environmental Quality Act (“CEQA”) guidelines. <br /> <br />The HAA provides the project legal protections. It requires approval of zoning and general <br />plan compliant housing development projects unless findings can be made regarding <br />specific, objective, written health and safety hazards. (Gov. Code, § 65589.5, subd. (j).) The <br />HAA also bars cities from imposing conditions on the approval of such projects that would <br />or reduce the project’s density unless, again, such written findings are made. (Ibid.) As a <br />development with at least two-thirds of its area devoted to residential uses, the project falls <br />within the HAA’s ambit, and it complies with local zoning code and the City’s general plan. <br />Increased density, concessions, and waivers that a project is entitled to under the DBL (Gov. <br />Code, § 65915) do not render the project noncompliant with the zoning code or general plan, <br />for purposes of the HAA (Gov. Code, § 65589.5, subd. (j)(3)). The HAA’s protections therefore <br />apply, and the City may not reject the project except based on health and safety standards, as <br />outlined above. Furthermore, if the City rejects the project or impairs its feasibility, it must <br />conduct “a thorough analysis of the economic, social, and environmental effects of the <br />action.” (Id. at subd. (b).) <br /> <br /> <br />2201 Broadway, PH1, Oakland, CA 94612 <br />www.calhdf.org