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know in advance if their proposed design will satisfy the City on this point, and thus the standard violates SB 330 and the HAA. • B4.1 This states, "Roof planes shall be subdivided to correspond to variations in building massing by bays,gables,dormers,and strong eave elements."What it means to "correspond to variations in building massing" needs further clarity; as it stands, this standard is not objective. • B51 This standard requires building facades to "clearly relate to each other and communicate a cohesive idea."The potential universe of meanings for this phrase is so vast that it can fairly be called meaningless.At best,it is completely subjective and hence unenforceable under SB 330 and the HAA. • B5.3: This states that certain facades must use"high quality materials including brick, stone, masonry, and tile." The enumeration of specific materials is acceptable; the phrase"high quality materials"is not. • B5.4: This standard tells developers, "Accessory Dwelling Units and other structures on each lot shall be designed to appropriately relate to the main dwelling in context and detailing." CaIHDF understands the City wants to maintain architectural consistency between structures on the same lot, but it cannot use such vague language to accomplish this goal. Whether a structure "appropriately relates" to another"in context and detailing"is far from an objective judgment In the proposed Objective Design Standards for Multi-family Housing in R-M,C-C,and M-U Zoning Districts: • A4.2: This standard prohibits "[s]tandardized exterior architecture (franchise architecture)," a phrase that sits very far from the territory of objective definitions. How is "standardization" to be measured? How far must a proposed design depart from "franchise architecture" to satisfy this standard? These and other questions leave more room than state law allows for the City to impose its subjective preferences on housing projects. • Baz This mirrors standard A7.8 in the proposed standards for the housing element site inventory,discussed above.The same objections apply here. • C11: This standard bars "[m]onolithic building massing" and requires building massing to "establish a rhythm composed of individual elements at a maximum spacing of 25 feet." The first phrase here has no clear, objective meaning ascertainable by reference "to an external and uniform benchmark or criterion,"as required by state law.The second phrase is better-"a maximum spacing of 25 feet"is certainly objective - but what it means to "establish a rhythm" is ambiguous. The proposed standards must clarify this language or excise it. • C3.3: This mirrors standard 84.1 in the proposed standards for the housing element site inventory,discussed above.The same objections apply here. • C7.1(c):This standard mirrors standard B3.2 in the proposed standards for the housing element site inventory,discussed above.The same objections apply here. 5of6