Skip to main content
HCD Logo

California Department of
Housing and Community Development

Inventory of Suitable Land

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.

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).


(916) 263-2911

Drawing of community plan

Requisite Analysis

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.

Sites Inventory:

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:

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:

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

Site Suitability

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:

Helpful Hints

Sample Analyses


Other Technical Assistance and Resources