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<br />ALAMEDA COUNTY <br />COMMUNITY DEVELOPMENT AGENCY <br /> <br /> <br />March 17, 2026 <br /> <br />VIA EMAIL: <br />XXXXX@XXXXX.XXX <br /> <br />TBD, TBD <br />Association of Bay Area Governments <br />Bay Area Metro Center <br />375 Beale Street, Suite 800 <br />San Francisco, CA 94105 <br /> <br />Subject: Transfer of Regional Housing Needs Allocations and Credits between <br />County of Alameda and City of Pleasanton <br /> <br />Dear TBD: <br /> <br />On behalf of the County of Alameda (County) and the City of Pleasanton (City), this letter is <br />intended to transmit and memorialize a mutually acceptable agreement regarding the transfer of <br />a portion of the County’s Regional Housing Needs Allocation (RHNA) responsibility to the City <br />associated with the annexation by the City of the “Merritt Property,” which was finalized by <br />Alameda County LAFCo on February 4, 2026, pursuant to Government Code Section <br />65584.07(d). <br /> <br />Government Code Section 65584.07(d) encourages counties and cities to reach a "mutually <br />acceptable agreement" for transferring RHNA related to a city's annexation of unincorporated <br />land. If such an annexation occurs after the council of governments (COG – here, ABAG) has <br />made its final RHNA allocation, the affected county and city may agree to transfer part of the <br />county’s allocation to the city. The transfer agreement must be submitted to the COG within 90 <br />days after the annexation. However, the COG may extend the deadline if an extension aligns <br />with the objectives of the Housing Element Law (Government Code Section 65584.07, subd. <br />(d)(2)(A)). A transfer agreement submitted under Government Code Section 65584.07(d) “shall <br />be effective immediately upon receipt by the COG" (Government Code Section 65584.07, subd. <br />(d)(2)(A)). A RHNA transfer under this section “shall be based on the RHNA methodology <br />adopted by the COG pursuant to Government Code Section 65584.04." However, the statute <br />states that the RHNA transfer “shall not be made” if the COG confirms that the annexed land <br />was fully incorporated into the RHNA methodology used to allocate the city’s share of the <br />regional housing needs (Government Code Section 65584.07, subds. (d)(2)(A) and (d)(3)). <br /> <br />As outlined below, the County and the City believe the RHNA transfer agreement meets all <br />applicable statutory criteria to be effective immediately upon receipt by ABAG. <br /> <br /> <br />Page 55 of 242