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Planning Commission <br />City of Pleasanton <br />December 14, 2022 <br />Page 2 <br />I. The City Must Assign Appropriate General Plan Land Use Designations <br />to Each HEU Inventory Site. <br />At present, the proposed General Plan land use designations for each of the HEU <br />inventory sites are unclear. For example, nothing in the HEU clearly identifies the <br />proposed General Plan land use designation for each inventory site, including those <br />requiring a rezoning, and the ODS describes the “General Plan Land Use <br />Designation / Zoning” for each site as “TBD [to be determined]”. (Draft ODS, Table <br />2.1.)2 It is therefore unclear how each site would be accommodating the units the <br />HEU assumes can and would be developed. <br />To provide the required certainty regarding the basic development standards that <br />will apply to each site and confirm that each can actually accommodate the HEU’s <br />assumed densities without undergoing a General Plan amendment, the City must <br />identify specific General Plan land use designations for each of the HEU inventory <br />sites. Each designation must accommodate the type and density of units <br />anticipated for the relevant portion of each site.3 This clarification is necessary to <br />ensure that the HEU complies with state housing law. (See Gov. Code, §§ <br />65583(a)(1), (c)(1)4; 65583.2(c)5; and 65302.) <br />2 Similarly, the Draft Environmental Impact Report (“DEIR”) for the HEU depicts six of the <br />HEU sites requiring rezoning as part of the HEU process (each, “rezone site”) as having two <br />apparently overlapping, projected General Plan land use designations. <br />3 For the Kiewit Site, this would involve: (1) designating an approximately 5-acre portion of <br />the site with a medium to high-density General Plan land use designation that allows for <br />development of affordable, multi-family units the HEU contemplates in this area and that is <br />proposed by the Kiewit Project; and (2) designating the remaining approximately 45-acre <br />portion of the site with a low or medium density designation that allows for development of <br />single family market rate units that the HEU contemplates and that is proposed by the Kiewit <br />Project. This could involve assigning a 5-acre portion of the Kiewit Site the General Plan’s <br />existing High Density Residential (HDR) land use designation and the approximately 45-acre <br />portion of the site a Medium Density Residential (MDR) designation. Seefried has provided <br />the City with a proposed General Plan land use map exhibit that is consistent with designs <br />for the Kiewit Project. <br />4 Government Code section 65583(c)(1) requires the City to identify actions, including <br />appropriate zoning and development standards, that will accommodate the City’s RHNA for <br />each income level on those sites that must be rezoned to allow for housing development. <br />5 Government Code section 65583.2(c) requires a housing element inventory to specify the <br />number of units that can realistically be accommodated on a site and whether the site is <br />adequate to accommodate lower income, moderate-income, or above-moderate income <br />housing. <br />Attachment 4 - ODS Public Comments - 01-26-23 CC - Page 2