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rPIPER April 18, 2022 Page Four However, neither the applicable interim standards under Specific Development 84 plan nor the Harbor Specific Plan allow the Lined Block typology at the Sites, but the more intensive Flex Block typology is allowed under Specific Development 84's CDR standards. However, it may be the case that, for the Sites and other sites within Focus Areas, the less intensive Lined Block typology would provide the most efficient, advantageous building design. And even though the Lined Block typology is less intensive than the Flex Block typology, a Flex Block building would be allowed at the Sites but a Lined Block building would not. To eliminate the potential for eliminating advantageous development design opportunities, we request language be added to the General Plan indicating that, where an interim development standard allows a certain building typology, any less intensive typology can also be allowed at the same location. This would provide new development applicants and City decisionmakers the flexibility to consider the best design for the particular site at issue. III. Clarify the Applicability of FAR and Density Limits in Focus Areas The applicable development standards in the Land Use Element for Focus Areas and, in particular here, the UN-30 designation, alternatively state that the applicable Floor Area Ratio ("FAR") and Density is 1.5 FAR and/or 30 du/ac," but elsewhere they state the standards is 1.5 FAR or 30 du/ac." (See, e.g., GPU, at pp. LU-23, LU-40.) These differing statements may create ambiguity as to whether the Land Use Element's respective FAR and density limits both apply to development projects or whether they apply in the alternative, the latter of which could create confusion and cause unintended consequences. In the absence of this point of clarity, it may be unclear to staff and future zoning ordinance drafters how the applicable FAR and density standards should be applied. If applied in the alternative, for example, a mixed-use project may not be able to fully utilize available density while also providing the full scope of job-producing commercial uses within the allowed FAR, e.g., if a project's density is maxed out at less than a 1.5:1 FAR, a project could be prohibited from adding additional floor area for commercial uses up to the 1.5:1 FAR limit. We do not believe such a result is what is intended by the standard, especially given the already conservative 1.5:1 FAR limit applied in the UN-30 zone. Thus, we request the Land Use Element be updated to state 1.5 FAR and/or 30 du/ac"wherever density and FAR limits cited and eliminate all references that only include the word "or." The same change should be made for other land use designations presenting the same issue. This revision would clarify the applicable standard and avoid potential confusion. WEST\298365149.1