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8.A. - Page 124 <br /> As HCD states .. . <br /> ... while it may be possible to build housing on a small lot, the nature and <br /> conditions (i.e., development standards) necessary to construct the units <br /> often render the provision of affordable housing infeasible. For example, <br /> assisted housing developments utilizing State or federal financial <br /> resources typically include 50 -80 units. To utilize small sites to <br /> accommodate the jurisdictions share of the regional housing need for <br /> lower- income households, the element must consider the impact of <br /> constraints associated with small lot development on the ability of a <br /> developer to produce housing affordable to lower- income households. <br /> (HCD, Analysis of Sites and Zoning, avail. at <br /> http: //hcd.ca.gov/hpd/housing element2 /SIA zoning.php #capacity). These small <br /> parcels are unlikely to support affordable housing and the City must provide <br /> justification for their inclusion. <br /> On the whole, the City does a good job of analyzing the current uses on sites it <br /> characterizes as underutilized. However, it appears to overreach on some parcels, <br /> and HCD should examine the analysis of each parcel closely. For example, <br /> Downtown Site 8, currently occupied by Chase Bank and the San Mateo County <br /> Law Library, is included in the inventory based, it appears, on its prime location, <br /> large surface parking (indicating it is underutilized), and vaguely described <br /> "discussions with property owners in the past regarding redevelopment." There is <br /> no indication that the extant businesses are blighted, outdated or have any plans to <br /> move. <br /> HCD calls for analysis of "[t]he condition or age of existing uses and the potential <br /> for such uses to be discontinued and replaced with housing (within the planning <br /> period)" (HCD, Analysis of Non - vacant and Underutilized Sites <br /> http: //hcd.ca.gov/hpd /housing element2 /SIA zoning.php #nonvancant) for each <br /> site that a city plans to include as underutilized. While Redwood City includes <br /> this information for some sites, it notably fails to do so as to Downtown Site 8 and <br /> others, making them suspect. Since these non - vacant sites constitute the bulk of <br /> Redwood City's site inventory, it is imperative that the potential for <br /> redevelopment of these sites be fully analyzed. <br /> Troublingly, one of the sites that falls into this category— Downtown Site 5— <br /> contains an apartment building as one of its current uses. While the affordability <br /> level of these apartments is not stated, it seems highly likely that rents at the new <br /> 100 -unit development that Redwood City projects will be built on the site will be <br /> higher than rents at the current building. Nor is the condition of the building or <br /> the fact that relocating tenants is a significant impediment to redeveloping the <br /> site. Particularly when the sites at issue would result in the removal of existing <br /> housing, Redwood City should be required to explain in detail how this site is <br /> truly underutilized by following HCD's guidance. <br /> 4 <br />