Inventory of Suitable Land
Government Code Section 65583(a)(3) requires local governments to prepare an inventory of land suitable for residential development, including vacant sites and sites having the potential for redevelopment, and an analysis of the relationship of zoning and public facilities and services to these sites. The inventory of land suitable for residential development shall be used to identify sites that can be developed for housing within the planning period (Section 65583.2).
The purpose of the land inventory is to identify specific sites that are suitable for residential development in order to compare the local government’s regional housing needs allocation (RHNA) with its residential development capacity. The inventory will assist in determining whether there are sufficient sites to accommodate the regional housing need in total, and by income category. A thorough sites inventory and analysis will help the locality determine whether program actions must be adopted to “make sites available” with appropriate zoning, development standards, and infrastructure capacity to accommodate the new construction need. Preparing the inventory and accompanying site-suitability analysis is a two-step process.
The housing element must identify specific sites or parcels that are available for residential development. Land suitable for residential development must be appropriate and available for residential use in the planning period. Identified sites that require rezoning may be included in the inventory, provided the housing element includes a program to accomplish the rezoning early within the planning period. Other characteristics to consider when evaluating the appropriateness of sites include, physical features (e.g. susceptibility to flooding, slope instability or erosion, or environmental considerations) and location (proximity to transit, job centers, and public or community services). Land suitable for residential development includes all of the following:
- vacant sites that are zoned for residential development.
- vacant sites that are not zoned for residential development, but that allow residential development.
- Underutilized sites that are zoned for residential development and capable of being developed at a higher density or with greater intensity.
- sites that are not zoned for residential development, but can be redeveloped for, and/or rezoned for, residential use (via program actions).
The inventory can also include sites that are in the process of being made available (i.e. planned) for residential uses via rezones or specific plans, provided the housing element includes a program that commits the local government to completing all necessary administrative and legislative actions early in the planning period.
The inventory must include all of the following:
- A parcel-specific listing of sites, including the parcel number or other unique reference, such as the address. Sites identified in the inventory as available to accommodate the RHNA for above moderate-income households, located in areas not served by public sewer systems, need not be listed on a parcel-by-parcel basis.
- The general plan and zoning designations of sites.
- A description of parcel size. This is important as parcel size can be a key factor in determining development viability, capacity and affordability.
- A map showing the location of sites. In terms of scale, a jurisdiction’s general plan land-use diagram or map is appropriate.
- A description of existing uses of any non-vacant sites.
- A general description of any known environmental constraints/
- A general description of existing or planned water, sewer, and other dry-utilities supply, including the availability and access to distribution facilities.
The following table is an example of a basic inventory of sites.
|Available Land Inventory Summary|
|Assessor Parcel Number||Zone||Allowable Density||General Plan Designation||Acres||Realistic Unit Capacity||Existing Use||Infrastructure Capacity||Onsite Constraints|
|041-0042-002||R-3||20-30 du/ac||Multifamily Residential||2.0||40||Vacant||Yes||None|
|037-0400-027||R-2||10-20 du/ac||Multifamily Residential||0.75||7||Duplex||Increases
in the Capital Improvement Program
|038-0100-040||R-1||5-10 du/ac||Single-Family Residential||4.5||22||Vacant||Max
|Wetlands can be mitigated|
|039-1100-039||CMU||20 du/ac||Mixed Use Commercial||1.5||25||Parking Lot||Yes||Partial Floodplain|
Preparation of a site-suitability analysis is the second step in addressing the adequate sites requirement. In addition to providing a listing of sites, local governments must prepare an analysis that demonstrates which identified sites can accommodate the housing needs, by income level, within the planning period of the housing element.
Housing Sites Controlled by an Exempt Entity (State, Federal, Tribal Nation)
Sites located on land controlled by exempt entities (e.g. college/university, military, recognized Native American tribes) are different from housing capacity planned on sites controlled by local governments. This is because the local government has no control over the planning and decision-making processes of land within another entity’s boundary, and, therefore, may not be able to demonstrate “sufficient certainty” that housing development on sites controlled by other entities could occur within the planning period to meet (or lessen) the requirement for the local government to identify adequate local sites to meet all of the jurisdiction’s RHNA.
HCD recognizes that the development of new housing on exempt-entity sites can meet a portion of a local government’s RHNA. For planned housing on exempt-entity sites, HCD allows — on a case-by-case basis — RHNA credit when documentation is provided that demonstrates the likelihood that the planned housing can be developed within the current RHNA/housing element. Adequate documentation varies based on differences in the planning processes on land controlled by exempt federal, state, or tribal entities (and counties in connection with sites within a city’s sphere of influence). Following are examples of documentation to help demonstrate the likelihood of housing being developed on sites near, but outside the control of, a local government:
- Agreement with the entity controlling the land that grants the local government authority regarding approving, permitting, certifying occupancy, and/or reporting new units to the California Department of Finance.
- Documentation from the entity controlling the land that demonstrates planned housing has been approved to be built within the current RHNA cycle. (Note: Short- or long-term housing development budgets or plans typically do not constitute adequate approval, because changes can occur.)
- Data pertaining to project construction and unit affordability by household income category.
- The development suitability requirement addressing zoning, density, realistic development capacity, lot size, and existing use(s) must be done on a parcel/site-specific basis.
- Local governments should consult with the for- and nonprofit development community for the purposes of soliciting information about site- and zoning-related factors that are useful in helping to reduce development costs.
- For the purpose of mapping small or scattered housing-opportunity sites (e.g. sites along commercial corridors or within adopted specific plan areas) local governments can use community plan or neighborhood scale maps or aerials.
- To further assist the development community in selecting potential development sites, a local government could post the inventory on its website.
- To ensure the inventory remains a viable and useable land-use planning tool throughout the planning period, local governments should prepare periodic updates (e.g. in conjunction with the annual, general-plan progress report).
- Sample Sites Inventory (PDF)
- Sites Inventory Template (2014) — Association of Bay Area Governments (XLS)
- The following files contain examples of parcel specific inventories of available sites prepared by the City of Citrus Heights and Sonoma County. Note the parcel specific identification, including an indication of zoning, general plan designation, parcel size, and existing uses. The added features of having links to aerials (Citrus Heights) and actual photos of the sites (Sonoma County) makes these examples especially useful in determining the appropriateness of the identified sites and providing an effective resource for the development community. A detailed site suitability analysis and constraints summary must be included with the parcel specific listing (not included with these examples).