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10 or fewer housing units. Staff disagrees with this argument and has indicated to the applicant that the entire project, including the Shriners property, would be subject to Measure PP since it is proposed as a cohesive project, proposed and to be developed under a single application comprising more than 10 units. Staff believes that "piecemealing" or carving out a sub -part of a larger project that would otherwise be subject to Measure PP appears contrary to the intent of the voter -approved measure. While staff believes the entire project is subject to Measure PP, some policy questions arise in the specific application and interpretation of the Measure with respect to this project. Although Ponderosa's proposal has been designed to minimize or reduce development on the site's steeper areas, the project nonetheless includes construction (grading, creation of residential lots and placement of roads) that involve slopes of 25 percent or greater. Key in the consideration of the project relative to Measure PP is the fact that the text of the measure does not define key terms, including `structure' `ridgeline' and `slope.' As such these key terms are potentially subject to differing interpretations. As noted, in 2016 the City undertook the Southeast Hills mapping process, in an effort to provide more clarity around the interpretation and applicability of Measure PP. With the adoption of the Southeast Hills area mapping and methodology, individual project sites are expected to use the methodology adopted (Exhibit D) to map their sites, "but could show a finer -grained pattern of areas subject to Measure PP (and areas not subject to Measure PP) The ultimate objective of each project -specific mapping would be to follow the restrictions of Measure PP while allowing for development of those areas not subject to Measure PP, or other limitations imposed by the General Plan, or other environmental considerations. In addition, definition and consideration of other concepts related to Measure PP (e.g., the definition of `structure' and whether artificial slopes should be excluded from Measure PP restrictions) would be undertaken at a project -specific level, per Council direction. For the subject property, staff used the methodology adopted by City Council to identify areas on the project site with a slope of 25 percent or greater, based on the City's GIS -based topographic data; the applicant's grading and lot layout plan was then overlain onto the mapping (see Figure 7, and Exhibit G). Areas with a slope of 25 percent or greater are shown as the reddish -pink color on the map and those areas with a slope of less than 25 percent are shown in green. The white lines shown reflect the proposed contour lines as a result of grading. The results of this methodology show areas of various sizes, some extensive and some much smaller, that contain a slope of 25 percent or more, that coincide with grading, roads, or the proposed residential lots. The most significant overlap between these slope areas and the project are in conjunction with new roads, including the EVA. There are also lots that would contain slopes of 25 percent or more (Lots 1-4, 10, 11, and 19 Figures 8 and 11); and/or areas of grading involving slopes greater 25 percent, necessary to facilitate the creation of individual lots (Lots 11, 18, and 31 in Figures 8, 9, and 12). P18-0078IP18-00791P18-00801P18-0081/PUD-130 Planning Commission 10807, 11021, and 11033 Dublin Canyon Road and the parcel west of 11021 Dublin Canyon Road 13 of 26