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8.A. - Page 118 <br /> NPH strongly suggests the city include the following programs in future iterations of <br /> the draft housing element: <br /> • Include an analysis of how opportunity sites score against site inventory <br /> criteria for LIHTC to assess feasibility and likelihood of affordable housing <br /> development occurring on these sites. <br /> Housing Opportunity Sites <br /> Tables H -56 and H-57 list the opportunity sites designated to accommodate RHNA for <br /> lower income households. The City estimates that the total realistic capacity that can be <br /> accommodated in each of these parcels is 90% of the maximum allowable density <br /> ranging from 40 -74 dwelling units per acre. By the City's estimation, the realistic <br /> capacity of the selected parcels will provide a surplus of housing across all affordability <br /> levels. <br /> At least 5 of the 11 downtown opportunity sites (Table H -56) have existing uses such as <br /> a bank, grocery outlet, and other commercial uses. In addition, a number of the parcels <br /> are either oddly shaped or are less than an acre in size both of which affect the <br /> feasibility of multi - family development. <br /> Analysis provided in the HE assumes that increased density equal affordability. In fact, <br /> research published by the Urban Land Institute demonstrates that there is an <br /> increased demand, across all affordability categories, to live closer to work and mass <br /> transit. Given the increased demand to live in transit- and amenity -rich communities, it <br /> is highly unlikely that any housing built without affordability protections will be <br /> affordable to those earning very- or low- income wages. <br /> Given the high need, affordable housing should be the first and highest priority when <br /> any kind of incentive (e.g. increased FAR or density) is provided in any development <br /> occurring within the City boundaries. This policy should not be limited to specific plan <br /> or precise plan areas. <br /> NPH strongly suggests the city include the following programs in future iterations of <br /> the draft housing element: <br /> • Include a program to adopt an affordable overlay zone for all identified <br /> opportunity sites. <br /> 6 Jonathan D. Miller, 2012 Emerging Trends in Real Estate (Washington, D.C.: PwC and the Urban <br /> Land Institute, 2011), 1, http: / /chicago.uli.org/wp- content /uploads /2012 /03/ET_US2012.pdf <br />