Planning Commission Supplemental Materials 11-12-25 (2)

7 3. Land Use Consistency For purposes of determining eligibility under Public Resources Code Section 21080.66, a proposed project is deemed consistent with the applicable general plan and zoning if there is substantial evidence that would allow a reasonable person to conclude that the project is consistent with either. Section 21080.66(a)(4)(B) expressly provides that, in instances where the general plan and zoning ordinance are not consistent with one another, a housing development project shall be considered consistent with both if it is consistent with either one. The proposed project is consistent with both the general plan land use designation and the zoning for the project site. Both the General Plan land use designation and the project site zoning include a Housing Element Overlay; the project site is listed as Area 19–Black Avenue in the City’s 2023–2031 (6th Cycle) Housing Element Update. Accordingly, the proposed project aligns with the permitted uses, development intensity, and design standards outlined in the City’s planning documents. The proposed project does not require a general plan amendment or rezoning and complies with all objective standards in effect at the time the preliminary application was submitted. Although the proposed project may utilize provisions under the State Density Bonus Law or the Housing Accountability Act, such provisions do not render the proposed project inconsistent with the General Plan or zoning for purposes of CEQA exemption eligibility under Public Resources Code Section 21080.66(a)(4). As such, the proposed project meets the land use consistency requirements of PCR Section 21080.66. 4. Density Requirements Public Resources Code Section 21080.66(a)(5) requires that the proposed project’s density be at least 15 units per acre. The proposed project achieves a net density between 22.8 and 25.5 units per acre (based on at least 59 and up to 66 units on 2.59 acres), which exceeds the threshold. Therefore, the proposed project meets the density criterion necessary to qualify for the CEQA exemption under Section 21080.66. Moreover, this density supports the City’s housing goals and contributes toward meeting its Regional Housing Needs Allocation (RHNA) obligations. The proposed project’s density is appropriate for the site’s urban context and is consistent with surrounding development patterns. 5. Environmental Constraints–Evaluation of Restricted Areas Based on a review of publicly available environmental databases, maps, and technical studies, the proposed project site does not contain and is not located within or adjacent to any of the following restricted or environmentally sensitive areas that would disqualify it from the CEQA exemption under Public Resources Code Section 21080.66(a)(6): • Wetlands. The project site is fully developed with urban uses and does not contain wetlands identified by the United States Fish and Wildlife Service (USFWS) National Wetlands Inventory.1 1 United States Fish and Wildlife Service (USFWS). 2025. National Wetlands Inventory (Web Viewer). Website: https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/. Accessed August 19, 2025.