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Step 3: Size of Sites

Housing Element Sites Inventory Guidebook (AB 1397) · 2026 edition · updated 2026-07-29 · California

Government Code section 65583.2(c)(2)(A), (B), and (C)

NEW Is the size of the site appropriate to accommodate housing for lower income households?

To achieve financial feasibility, many assisted housing developments using state or federal resources are between 50 to 150 units. Parcels that are too small may not support the number of units necessary to be competitive and to access scarce funding resources. Parcels that are large may require very large projects, which may lead to an over concentration of affordable housing in one location, or may add cost to a project by

Site Inventory Guidebook

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May 2020

requiring a developer to purchase more land than is needed, or render a project ineligible for funding. If the size of the site is smaller than one half acre or larger than 10 acres, the following analysis is required.

If the parcel is more than 0.5 acres or less than 10 acres, is the size of the site automatically considered appropriate to accommodate lower income RHNA?

Not necessarily. If the size of the parcel in combination with the allowable density and accompanying development standards cannot support a housing development affordable to lower income households, further analysis and programs may be needed to demonstrate the suitability of that site to accommodate the portion of the RHNA for lower income households. End Question and Answer

Is the size of the parcel under 0.5 acres? If Yes: Move to Step 3A

Is the size of the parcel over 10 acres? If Yes: Move to Step 3B

If No to Both: Move to Part C: Capacity Analysis

Step 3A: Sites smaller than 0.5 acres

A parcel smaller than one half acre is considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on these sites is realistic or feasible. While it may be possible to build housing on a small parcel, the nature and conditions (i.e., development standards) necessary to construct the units often render the provision of affordable housing infeasible. The housing element must consider and address the impact of constraints associated with small lot development on the ability of a developer to produce housing affordable to lower income households. To demonstrate the feasibility of development on this type of site, the analysis must include at least one of the following:

  • An analysis demonstrating that sites of equivalent size were successfully developed during the prior planning period with an equivalent number of lower income housing units as projected for the site.

  • Evidence that the site is adequate to accommodate lower income housing. Evidence could include developer interest, potential for lot consolidation, densities that allow sufficient capacity for a typical affordable housing project, and other information that can demonstrate to HCD the feasibility of the site for development. For parcels anticipated to be consolidated, the housing element must include analysis describing the jurisdiction’s role or track record in facilitating small lot consolidation, policies or incentives offered or proposed to encourage and facilitate lot consolidation, conditions rendering parcels suitable and ready for consolidation such as common ownership, and recent trends of lot consolidation. The housing element should include programs promoting, incentivizing, and supporting lot consolidations and/or small lot development.

  • • A site may be presumed to be realistic for development to accommodate lower income housing need if, at the time of the adoption of the housing element, a development affordable to lower income households has been proposed and approved for development on the site.

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May 2020

The housing element must also describe existing and proposed policies or incentives the jurisdiction will offer to facilitate development of small sites. Examples of program incentives for lot consolidation include deferring fees specifically for consolidation, expediting permit processing, providing flexible development standards such as setback requirements, reduced parking or increased heights, committing resources for development of affordable housing on small sites, or increasing allowable density, lot coverage or floor area ratio.

Step 3B: Sites larger than 10 acres

Parcels larger than 10 acres are considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on such sites was successful during the prior planning period, or there is other evidence that the site is realistic and feasible for lower income housing.

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Contents — Housing Element Sites Inventory Guidebook (AB 1397)
Housing Element Sites Inventory Guidebook (AB 1397)
  1. SUBJECT: Housing Element Site Inventory Guidebook Government C…
  2. Housing Element Site Inventory Requirements
  3. SITE INVENTORY GUIDEBOOK FRAMEWORK
  4. PART A: IDENTIFICATION OF SITES
  5. PART B: SITES TO ACCOMMODATE LOW AND VERY LOW- INCOME RHNA
  6. PART C: CAPACITY ANALYSIS
  7. PART D: NONVACANT SITES
  8. PART E: DETERMINATION OF ADEQUATE SITES
  9. Step 1: Identification of Developable Sites Government Code se…
  10. Government Code section 65583.2(b)
  11. Step 3: Infrastructure Availability Government Code section 65…
  12. Step 4: Map of Sites
  13. Step 5: Determination of Consistency with Affirmatively Furthe…
  14. Government Code section 65583.2(c)
  15. HCD Best Practices for selecting sites to accommodate the lowe…
  16. Step 7: Environmental Constraints
  17. NEXT STEP:
  18. Step 1: NEW Sites Used in Previous Planning Periods Housing El…
  19. Unusual Circumstances
  20. Step 1B:
  21. Definition of Use By Right (Government Code section 65583.2 (i))
  22. Sample Program:
  23. Government Code section 65583.2(c)(3)
  24. Housing Overlays
  25. Step 3: Size of Sites
  26. Definition of a Large Site
  27. Specific Plans, Master Plan, and other Subdivisions
  28. NEXT STEP:
  29. Step1: Utilizing minimum densities to calculate realistic capa…
  30. Government Code section 65583.2(c)(2)
  31. - Applicable land use controls and site improvement requirements
  32. Form Based Codes
  33. Typical densities of existing or approved residential developm…
  34. No Net Loss Law
  35. NEXT STEP:
  36. Definition of a Vacant Site
  37. Step 1: Description of the nonvacant site Government Code Sect…
  38. Government Code section 65583.2(g)(1)
  39. Existing Uses:
  40. Development Trends:
  41. Market Conditions:
  42. Availability of Regulatory and/or other Incentives:
  43. Step 3: NEW Reliance on nonvacant sites to accommodate more th…
  44. Step 4: NEW Program and policy requiring replacement of existi…
  45. Program X: Replacement Unit Program
  46. Funding: General Funds
  47. NEXT STEP:
  48. Government Code section 65583.1
  49. Impact of New Accessory Dwelling Unit Laws
  50. Step 2: Determine whether there is sufficient capacity to acco…
  51. Step 3: Adequate Sites Program
  52. General Program Requirements
  53. Timing
  54. Consequences for Failing to Complete Rezoning Deadline:
  55. Housing Accountability Act and the Housing Element
  56. Annexation
  57. Common Program Questions and Answers for Shortfall Zoning:
  58. ATTACHMENT 1: SUMMARY OF NEW LAWS REFERENCED IN THE GUIDEBOOK
  59. ATTACHMENT 2: GOVERNMENT CODE SECTION 65583.2

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