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a <br />a <br />create unacceptable impacts as determined by CEQA review and other studies." The letter <br />requests that the two references to "shall" be changed to "should." <br />Response: Staff does not recommend modifications to this Guiding Principle. The City must <br />consider the environmental impacts ofJuture development under CEQA, and in light of the City's <br />policies in areas such as trffic, emergency response times, etc. lilhile this analysis will be <br />required, the City has the ability to determine, following such analysis, whether to accept <br />impacts that may exceed established thresholds (e.g. through adoption of Statements of <br />Overriding Consideration), or through accepting an exceedance of standards set by policy based <br />on other community benefits that would be achieved by the project. <br />Summary of Comment: Allow for more flexibility in density product types...to provide for a <br />variety of housing and product types within the mall parcels. <br />Response: The Framework Concepts document, on Page l2 makes it clear that the 3-acre <br />housing allocations may a) be reallocated among the various owners and b) placed on sttes <br />larger or smaller than 3 ocres, provided that the minimum and maximum densities specified in <br />the Housing Element are met. Staff believes this provides adequate flexibility, ond strongly <br />recommends against allowingfor densities below the minimum, since it would be inconsistent <br />with the Housing Element, and the urban design and placemaking goals for the mall (for <br />example, f a large number of lower-density townhome units were allowed to be constructed, in <br />lieu of the same number of higher density oportment units with structured parking). <br />Summary of Comment: Recommend various modifications Section D: Design and Placemaking <br />Elements of the Framework Components to allow additional flexibility in future planning and <br />avoid creating an infeasible plan. <br />Response: Staffdoes not support the requested revisions, which include substantial changes to <br />the text, such as revisingwording in several placesfrom "shall" to "should," inserting language <br />to state any o.f the listed elements are "to be considered" in the Framework, and that none are <br />mandatory, delete specific dimensional standards and illustrative diagrams, and delete the <br />majority of more detailed requirements (e.g. for minimum open space ratios, active frontage <br />requirements, building orticulation and massing). <br />The design and placemaking elements, as stated, are intended as a starting point, recognizing <br />that they will be revised and refined os more detailed planningfor the Mall proceeds. Until those <br />standards are refined, the Housing Element's designation of the Mall as o housing site (or series <br />of sites), provides o property owner the ability to submit an application for a housing project, <br />with or without completion of the Framework or other planning. Staff believes it is in the best <br />interest of the City to have some standards in place, in the interim, and to provide guidance on <br />the City's expectations as plonning moves forward. <br />Nonetheless, recognizing the property owners concerns about these standards being treated as <br />binding, when some modification or adjustment to them may be necessary and appropriate as <br />more detailed plans are developed, staff recommends the prefacing statement in Section D be <br />clarified as follows: <br />Page 2