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Megan Campbell <br />December 5, 2022 <br />Page 2 <br />SEIP-58196\2713340.1 <br />1.The Project Description Should Identify the Specific General Plan Land <br />Use Designations that will be Applied to the Potential Sites for <br />Rezoning. <br />In the DEIR’s Project Description, six of the HEU sites identified for rezoning as part <br />of the HEU process (each, “rezone site”)are depicted with two apparently <br />overlapping, projected General Plan land use designations. The concern with this <br />approach is that it results in a project description that does not disclose the specific <br />type of land use(s) and related development standards –including, without <br />limitation, where or how residential units at different density ranges will be disbursed <br />–that will apply to each rezone site. It is therefore unclear how each site would be <br />accommodating the units the HEU assumes can and would be developed. <br />2 <br />To ensure the DEIR provides an accurate, stable, and consistent project description <br />as required under state law (see Gov. Code, §§ 653023, 65583.2(c)4), it is <br />necessary that the City assign one specific land use designation that <br />accommodates the type and number of units anticipated for the relevant portion of <br />each site. <br />For the Kiewit Site, this would involve: (1) designating an approximately 5-acre <br />portion of the site with the General Plan’s High Density Residential (“HDR”) <br />designation to coincide with the affordable, multi-family component contemplated by <br />the Kiewit Project; and (2) designating the remaining approximately 46.3-acre <br />portion of the site with the Medium Density Residential (MDR) designation to <br />correspond with the single-family units contemplated by the Kiewit Project. This <br />would reflect the exhibit the development plan Seefried has shown City staff, <br />attached hereto as Exhibit A. As contemplated, this proposed land use designation <br />map would facilitate construction of a high-quality affordable component that is <br />2 For example, five rezone sites are shown on Exhibit 2-5a and Table 2-9 as having both a <br />Mixed Use (MU) designation and Business Park (BP) designation. The General Plan’s <br />current MU designation allows for residential densities of 20+ units an acre, while the BP <br />designation apparently does not contemplate residential uses. (See General Plan Land Use <br />Element, Element, Table 2-3, pp. 2-23, 2-24.) The Kiewit Site is shown with overlapping <br />Medium Density Residential (MDR) and High Density Residential (HDR) designations. <br />These designations have different densities, with MDR allowing between 2 to 8 units per <br />acre, and the HDR designation allowing for 8+ units per acre (See General Plan Land Use <br />Element, Table 2-3, p. 2-22.) <br />3 Government Code section 65302 requires the land use element to designate the general <br />distribution and location of uses of land for housing, business, etc., with a statement of the <br />standards of population density and building intensity for the various districts and other <br />territory covered by a general plan. <br />4 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 />6(()5,(' <br />3DJHRI <br />