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rPIPER April 18, 2022 Page Two ("GPU"), at p. LU-68.) Notably, the proposed General Plan identifies multiple different sources of interim development standards for different Focus Areas. For example, for the Sites, three separate designations from two different plans apply as interim development standards: two designations from the Specific Development 84 plan: (1) Urban Neighborhood 2 ("UN-2"), and (2) Corridor ("CDR")—and one designation from the Harbor Mixed-Use Transit Corridor Specific Plan ("Harbor Specific Plan"): (1) Neighborhood Transitional. (GPU, at p. LU-74.) However, no statement is provided indicating how City staff and decisionmakers should address potential conflicts between such applicable interim development standards. As applied to the Sites, for one example, under the Harbor Specific Plan's applicable Neighborhood Transitional designation, banks and commercial gyms are prohibited uses. (Harbor Specific Plan, Table 3-2.) However, those same uses are allowed by right in CDR sites under the Specific Development 84 plan, and commercial gyms are allowed as a conditional use at UN-2 sites under that same plan. (Specific Development 84, Table 2A.) To resolve this issue, we request that the City Council provide direction to the City staff and decisionmakers that the City has the discretion to permit the least restrictive applicable interim development standards within a Focus Area. Such a direction would be necessary to ensure clarity in the applicability of standards within Focus Areas and provide the greatest range of flexibility and discretion to City decisionmakers while still being consistent with the proposed General Plan's designated interim development standards. Such a clarification is necessary to ensure that certain senseless unintended consequences cannot occur regarding conflicts between inconsistent applicable interim development standards. For example, the interim development standards that apply to the Sites permit different building types governed by City standards in a manner that, if the least restrictive standard applied, would effectively ban all of the City's allowed building typologies in the Focus Area. Specifically, Specific Development 84 plan's UN-2 prohibits Flex Block, Lined Block and Stacked Dwellings, but allows Hybrid Court and Courtyard Housing building types. (Specific Development 84, Table UN2-1.) However, Specific Development 84's CDR standards allow Flex Block buildings but prohibit Hybrid Court and Courtyard Housing typologies. Thus, if the most restrictive standard applied —none of the City's allowed categories of housing typologies would be allowed within the Focus Area. Such a result is clearly not what is intended in adopting interim development standards and underscores the need for the Council to provide clarity to City staff and decisionmakers that the least restrictive standards under applicable interim development standards should apply within General Plan update Focus Areas. WEST\298365149.1