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intensive use"below what was permitted as of January 1,2018."Less intensive use"includes, but is not limited to, "reductions to height,density,or floor area ratio,new or increased open space or lot size requirements, new or increased setback requirements, minimum frontage requirements, or maximum lot coverage limitations" (Gov. Code § 66300,sub d.(b)(1)(A)). Thus, the objective design standards under consideration at this week's Council meeting must not reduce the housing development potential of the lots they apply to. Absent significant amendments,however,the proposed standards risk doing exactly that. A. SB 330 Violations in the Proposed Standards for Housing Sites The proposed standards for sites included in site inventory of Pleasanton's draft Sixth Cycle Housing Element represent an update to the Housing Site Development Standards and Design Guidelines, adopted in 2012. Many of the sites in Pleasanton's draft Sixth Cycle Housing Element (which is also being considered at this week's Council meeting) were included in the Fifth Cycle Housing Element, and the proposed standards would therefore represent a change in design standards for these sites.To the extent the proposed standards are stricter than the guidelines adopted in 2012, and to the extent the proposed standards include new standards not in the 2012 guidelines,they risk a clash with SB 330's prohibition on downzoning with respect to these carryover sites. Sites that were not in the Fifth Cycle Housing Element represent a bigger problem.Because these sites are perforce not covered by the pre-existing guidelines,the proposed standards in many cases would create entirely new restrictions on housing development on these sites.That would violate SB 330. (A brief aside: some of the sites new to the site inventory in the sixth cycle are covered by design guidelines from other sources, such as the Downtown Specific Plan.Potential SB 330 problems for these sites arise to the extent the proposed standards tighten the rules from these other sources. These problems are similar to the SB 330 violations in the proposed standards for multi-family housing in R-M,C-C,and M-U zoning districts,discussed below.) B. SB 330 Violations in the Proposed Standards for Multi-family Housing in R-M, C-C, and M-U Zoning Districts The proposed standards for multi-family residential developments in R-M, C-C, and M-U districts,unlike the proposed standards for sites in the housing element site inventory,have no pre-existing counterpart.Various city regulations and ordinances(such as the Downtown Specific Plan and the Pleasanton Municipal Code) do contain design standards and guidelines that the proposed standards are meant to replace and make objective, but the 306