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Pleasanton's ability to develop needed <br /> housing, accommodate future regional share <br /> needs, or respond to change. If adopted, <br /> this ordinance should be analyzed as a <br /> constraint to housing development. <br /> <br /> d. We note the City currently assesses a lower- <br /> income housing fee (Housing Program 11.1) on <br /> each residential and non-residential project <br /> and is considering the implementation of <br /> inclusionary requirements for new residential <br /> developments to provide a minimum number of <br /> below-market-rate units (Housing program <br /> 9.5). Inclusionary ordinances have the <br /> potential to constrain the development of <br /> market rate housing by increasing the <br /> development costs for all housing. <br /> <br /> We do not support the City's adoption of <br /> inclusionary requirements and are very <br /> concerned that existing in-lieu fee and <br /> proposed land dedication requirements will <br /> add to the cost of housing for all levels. <br /> These additional costs could constrain the <br /> development of the market rate units upon <br /> which the inclusionary units depend. The <br /> element should include an analysis of Housing <br /> Program 11.1 and if Housing Program 9.5 is <br /> adopted, this program should also be analyzed <br /> as a potential constraint. In implementing <br /> any in-lieu fee or inclusionary program, the <br /> City should include sufficient incentives to <br /> facilitate both market-rate housing and the <br /> below-market rate housing that is tied to <br /> market-rate approvals. <br /> <br />The following information was contained in Appendix C <br />of supplement to the adopted housing element, but not <br />included in the current draft element: <br /> <br />· The draft element does not contain an analysis of <br /> the City's building codes and their enforcement. <br /> The required analysis of building codes and their <br /> enforcement should discuss any local amendments to <br /> State Housing Law or the model codes adopted into <br /> it by reference, and should analyze the type <br /> and/or degree of enforcement. <br /> <br />· The draft element lacks an analysis of <br /> Pleasanton's on- and off-site improvement <br /> requirements. The analysis of on- and off-site <br /> .improvement requirements could describe and <br /> <br /> 3 <br /> <br /> <br />