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California Department of
Housing and Community Development

Identify Adequate Sites


(916) 263-2911

Topics Covered

Please note, the information provided below does not reflect statutory changes enacted as of January 1, 2018 as part of the 2017 Legislative Housing Package. For additional information on the specific bills, provisions and timing for implementation, please visit our Legislative Housing Package webpage.



Drawing of district boundry lines

Identify actions that will be taken to make sites available during the planning period of the general plan with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city's or county's share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Section 65583(c)(1))

Required Components of Programs

Effective programs reflect the results of the local housing need analyses, identification of available resources (including land and financing), and the mitigation of identified governmental and nongovernmental constraints. Programs consist of specific action steps the locality will take to implement its policies and achieve goals and objectives. Programs must include a specific timeframe for implementation, identify the agencies or officials responsible for implementation, and describe the jurisdiction’s specific role in implementation.

Program Requirements

Last Updated: 12/9/16


The sites inventory should demonstrate adequate site capacity to accommodate the regional housing need for all income groups. Where the analysis of a local government’s sites inventory does not demonstrate enough suitable, available, and appropriately zoned sites to accommodate the regional housing need by income level, the housing element must include an adequate-sites program to identify sites that can be developed within the planning period. Sites or zones must be identified to facilitate and encourage the development of a variety of types of housing for people at all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, emergency shelters, and transitional housing.

A jurisdiction’s adequate sites program must accommodate 100 percent of the shortfall of sites necessary to accommodate the remaining housing need for housing for very low- and low-income households during the planning period. These sites must be appropriately zoned early enough in the planning period to provide realistic and viable development opportunities.

The program must:

By-Right Program Minimum Densities
Incorporated cities within nonmetropolitan/rural counties and nonmetropolitan counties with *micropolitan areas
Unincorporated areas in all nonmetropolitan counties not included under I
Suburban jurisdictions
Metropolitan jurisdictions
Nonmetropolitan counties with micropolitan areas include:

Del Norte
Note: Following list excludes those counties with *micropolitan areas as outlined in I

Note: Suburban jurisdictions include cities and counties located within a **Metropolitan Statistical Area (MSA) and have a population of less than 2 million. (Cities in a MSA with a population greater than 100,000 are considered metropolitan.)

San Benito
San Joaquin 
San Luis Obispo
Santa Barbara
Santa Clara
Santa Cruz Shasta
Note: Metropolitan jurisdictions include cities and counties located within a **Metropolitan Statistical Area (MSA) with a population of more than 2 million (Cities in a MSA with a population less than 25,000 are considered suburban.)

Contra Costa
El Dorado
Los Angeles
San Bernardino
San Diego
San Francisco
San Mateo
Density: At least 16 dwelling units/acre Density: At least 16 dwelling units/acre Density: At least 20 dwelling units/acre Density: At least 20 dwelling units/acre

*Micropolitan: Urban cluster of at least a 10,000 population, but less than a 50,000 population.
**Metropolitan Statistical Area (MSA): A city with 50,000 or more inhabitants, or the presence of an Urbanized Area (UA) and a total population of at least 100,000.

Definition of By-Right

For the purposes of housing element law and in accordance with Chapter 724, by-right shall mean the local government’s review shall not require:

This provision does not preclude local planning agencies from imposing design review standards. However, the review and approval process must remain ministerial and the design review must not constitute a “project” as defined in the Section 21100 of the Public Resources Code. For example, a hearing officer (e.g., zoning administrator) or other hearing body (e.g., planning commission) can review the design merits of a project and call for a project proponent to make design-related modifications, but cannot deliberate the project’s merits or exercise judgment to reject or deny the “residential use” itself.

Adequate-Sites Program Timing

A locality’s ability to accommodate needed housing during the planning period requires designating appropriate zoning as early as possible. The most direct procedure is for the locality to undertake rezoning when the housing element is adopted. The program must make provision for sites that will be available soon enough to reasonably permit development during the planning period. For example, rezoning actions should be completed within the first year to two years.

Policy and Program Options

Strategies to Increase Residential Capacity

The following approaches have been used by localities to increase their total residential development capacity:

Appropriate Development Standards

Appropriate zoning and development standards facilitate the location, siting, capacity, and price of residential development in order to meet identified housing needs, particularly new construction for lower-income households. These include establishing minimum densities and minimum floor areas; increasing maximum lot coverage; allowing minimum building-, rear-, and side-yard setbacks; reducing parking and amenities requirements; and other controls such as streamlined architectural and design review standards.
State zoning law requires localities to zone sufficient vacant land for residential use with appropriate standards to meet the housing needs as identified in the general plan. Appropriate standards are requirements that contribute significantly to the economic feasibility of producing housing at the lowest possible cost.
In regulating subdivisions, Government Code Section 65913.2 provides that a local government may not impose design criteria for the purpose of rendering an affordable housing development infeasible. A community may not impose standards and criteria for public improvements (e.g. streets, sewers, schools, or parks) that exceed those imposed on other developments in similar zones. Additionally, the effect of a community’s ordinances and actions on accommodating the housing needs of the region must be considered.

Encouraging Development of Underutilized Sites for Housing

Identification of underutilized land and opportunities for mixed uses must be accompanied by programs that encourage their development and/or reuse. Such programs could include actions to initiate any necessary rezoning, establish appropriate regulatory and/or financial incentives, relax development standards (design criteria, parking, building height, setback requirements, etc.), support more compact and higher-density residential developments, and facilitate the new construction of multifamily rental and owner-occupied units. Such developments are often located in urban core areas, adjacent to existing neighborhoods, close to transit centers, and near established businesses and services.

Strategies to Encourage Adequate Sites for a Variety of Housing Types

While the sites inventory may identify sufficient sites to accommodate the locality’s total share of the regional housing need, the element must also include policies and programs to promote development on identified sties. Localities have developed various strategies and development incentives to encourage a variety of housing types for all income levels, including:

Sample Program Format

Description of the specific actions, jurisdiction’s specific role in implementation and demonstration of commitment to implement
Objectives: (Quantified, where possible)
Responsible Agency: 
Funding Source(s)
: (Where appropriate)

Sample Programs

Sample Program 1: By-Right

To facilitate the development of multifamily housing affordable to lower-income households, the county will identify and rezone 30 acres of vacant land with the R3 zoning district, allowing exclusively residential uses and a minimum of 16 units per acre by June 30, 2020. Rezoned sites will be selected from sites 20 through 45 in the parcel listing (Appendix A), will be suitable, have the capacity for at least 16 units, and will be available for development in the planning period where water and sewer can be provided.
Objective: Create opportunity for at least 480 units of rental housing for lower-income households
Responsible Agency:
Community Development Department
Timeline: Sites rezoned by June 30, 2020
Funding Source(s): General fund

Sample Program 2: Rezone Program on Mixed-use Sites

To accommodate the remaining lower-income RHNA of 150 units, the City will identify and rezone 8 acres of sites within the MU-30 zoning district, allowing owner-occupied and rental multifamily residential uses “by-right”, at a minimum of 20 units per acre by June 30, 2017. Sites will allow projects to be 100 percent residential by-right but shall require residential uses to occupy at least 50 percent of the total floor area of the mixed-use project. Rezoned sites will be selected from sites 15 through 30 in the parcel listing (Appendix A), and have the capacity for at least 16 units per site.

Responsibility: Community Development Department
Timing: Sites rezoned by June 30, 2017
Funding: General Fund
Objective: Create opportunity for at least 150 units of rental housing for lower income households


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