Although developers may recognize value in responding to living patterns, extensive zoning policies often prevent affordable homes from being constructed within urban development. Due to urban density restrictions, rezoning for residential development within urban living areas is difficult, which forces the builder and the market into urban sprawl and propagates the energy inefficiencies that come with distance from urban centers. In a recent example of restrictive urban zoning requirements, Arcadia Development Co. was prevented from rezoning a parcel for residential development in an urban setting within the city of Morgan Hill, California. With limitations established in the interest of public welfare, a density restriction was applied solely to Arcadia Development Co.'s parcel of development, excluding any planned residential expansion.