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Court Of Appeal Applies Traditional Deferential Standard Of R... Page 2 of 4 commercial and retail services as well. From a land use perspective, the project necessitated an EIR and amendments to the general plan, zoning map and planning code, along with a local coastal permit and a development agreement. Following a recommendation for approval by the planning commission and approval by the Board of Supervisors, opponents filed suit, arguing general plan planning adequacy, consistency, due process, CEQA, and administrative record issues. The appellate court ordered published those portions of its decision pertaining to general adequacy, project consistency, due process, and the administrative record. While cities, counties and applicants may take questions of general plan adequacy for granted, this case is a reminder that legal sufficiency is an issue of ongoing relevance, long after a general plan has been adopted or amended. Opponents challenged standards of population density, building intensity and correlation of the circulation element with the land use element. In terms of the standard of review, the appellate court agreed with the trial court in applying the standard of whether a reasonable person could conclude that a combination of housing element tables and maps within the general plan satisfied the standards for recommended population density (which were sufficient in the eyes of the trial and appellate courts.) Turning to the challenged building intensity standards, the court determined that the respondent had satisfied this requirement through various maps and text of general plan, along with provisions of the Parkmerced special use district (a zoning district added to development code.) Finally, challenging the general plan under the correlation requirement (Government Code section 65302(b), the opponents argued that in the absence of building intensity standards, the circulation element could not be correlated with the land use element. The appellate court, having determined that sufficient intensity standards existed, rejected their argument as well. The court went on to note that the correlation requirement did not compel local governments to limit population growth or to avoid adverse impacts on transportation facilities. The appellate court then turned to the matter of general plan consistency, with the opponents arguing that the traditional deference to local agency interpretation of general plan policies did not apply when the policies were adopted by the citizenry. In the particular instance, this question had the added nuance in that the citizen measures were self labelled as priority http://blog.aklandlaw.com/2014/11/articles/cega/court-of-appeal-... 2/22/2015