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Cotati City Council
December 9, 2025

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December 9, 2025
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Cotati City Council
Agenda Staff Report
Item type: REGULAR AGENDA (ACTION)
To: City Council
Subject: INTRODUCTION AND FIRST READING OF ORDINANCE
AMENDING TITLE 17 (LAND USE) OF THE COTATI

MUNICPAL CODE TO CREATE THE SANTERO WAY (SW)

AND TRANSIT ORIENTED COMMUNITIES (TOC) ZONING

DISTRICTS, IMPLEMENT TOC-RELATED POLICY

REQUIREMENTS AND MAKE OTHER CLARIFYING

CHANGES TO THE COTATI MUNICIPAL CODE
Date: December 9, 2025
Written by: Noah Housh, Director of Community Development Recommendation
It is recommended by the Planning Commission and the Community Development Department that the City Council introduce and conduct the first reading of an ordinance to create the Santero Way (SW) and Transit Oriented Communities (TOC) zoning districts, to make additional zoning amendments to implement the Transit Oriented Communities (TOC) policy requirements from ABAG/MTC and to make other clarifying changes to the Cotati Municipal Code (CMC).

Background
In August 2001, the Santero Way Specific Plan (SWSP) was adopted, and originally envisioned a mixed-use office neighborhood adjacent to the SMART rail station. The primary objective of the original SWSP was to increase the number of residents and employees within walking distance (1/2 mile) of the SMART station. Specifically, the original Plan envisioned the development of 198 new dwelling units, 339,200 square-feet of office and institutional uses, 68,000 square-feet of retail uses, and 57,000 square feet of supporting parkland/open space.

On August 8, 2023, in response to stalled development within the Plan area, the City Council authorized the City Manager to enter into a professional services agreement with 4LEAF Inc. and several subconsultants to provide planning consulting services to complete the Santero Way Specific Plan Update.

In September 2023, the Association of Bay Area Governments (ABAG) and Metropolitan Transportation Commission (MTC) published draft administrative guidance on their TransitOriented Communities (TOC) policies. These policies are intended to intensify land uses within ½ mile of transit hubs with the primary goal of increasing the overall supply of housing while also supporting the creation of jobs and increasing transit ridership, in keeping with the Plan Bay Area 2050. For Cotati, this area primarily covers properties along East Cotati Avenue. These criteria essentially serve to increase residential and commercial densities, support alternative transportation, and reduce the perceived impediments to development. While adoption of the TOC policies is voluntary for Bay Area jurisdictions, TOC compliance will be required to retain eligibility for One Bay Area Grant (OBAG) funds by 2026, which have amounted to approximately $1,000,000 in annual funding for the City of Cotati in recent years. In April 2024, staff identified a potential opportunity for the environmental analysis being prepared for the SWSP Update to be expanded to additionally analyze the potential impacts of implementing ABAG/MTC TOC policies on the other eligible parcels within the ½ mile radius surrounding the Cotati SMART station (graphic attached). Including this analysis in the environmental impact report (EIR) already underway was approved in order to provide significant cost savings, expedite the analysis, and prepare the City for future adoption of the TOC policies. In February of 2025 the Santero Way Specific Plan (SWSP) was adopted after 18 months of public engagement, environmental analysis and policy development. One of the core themes of the SWSP is the focus on the neighborhood’s proximity to the SMART station and the benefits of intensified land uses around the train station. These themes are captured through a range of policy ideas often labeled Transit Oriented Development. As was discussed during the review of the Santero Way Specific Plan (SWSP), some of the policies adopted with the SWSP were influenced by the Association of Bay Area Governments (ABAG) and the Metropolitan Transportation Commission (MTC) Transit Oriented Communities (TOC) policy, which comes from their regional planning tool to manage growth in the nine counties of the San Francisco Bay Area, Plan Bay Area 2050+.

Plan Bay Area 2050+ is similar to a General Plan for a city or county but considers and plans for growth on a regional scale. ABAG/MTC identify goals and priorities to guide and manage Bay Area growth and use various methods to achieve compliance with the policies and programs, including allocation of grant funding such as the One Bay Area Grant (OBAG). In Cotati, OBAG provided significant funding for road infrastructure projects in recent years. For local jurisdictions seeking to comply with the Plan Bay Area, TOC has become one of the most impactful planning policies to come out of the 2050+ update process. This policy seeks to intensify land use in close proximity to transit stations and also standardize TOD development criteria throughout the Bay Area.

Because of the unique variety of jurisdictions and transit throughout the region, creation of the TOC policy implementation metrics has been an ongoing and iterative process spanning several years. Since the SWSP project was approved, implementation focus has moved from land use requirements within a ½ mile radius of the SMART station, to more broad policy requirements such as “The Three P’s of Housing”: Production, Preservation, and Protection; automotive and bicycle parking management; and efforts to facilitate circulation and station access. Required implementation of TOC policy is generally limited to the ½ mile radius around the transit stop (see pg. 27 MTC TOC Policy Version 1.1 May 2025), however the nature of some of the policy requirements make limiting enforcement to this geographic area of the City challenging.

In May 2025 the ABAG/MTC TOC policy guidance document was finalized allowing Community Development department staff to pivot their TOC policy efforts to the remaining properties within the broader half-mile radius from the SMART station not within the SWSP boundary. Due to the unique geography of the City, this primarily encompassed properties on E.

Cotati Avenue, from La Salle Avenue east to the SWSP. While demonstrating compliance with TOC policy direction is important to grant infrastructure funding, taking a thoughtful and community-informed approach to the land use changes in this established area is also critical to the successful implementation of these policies.

On June 25, 2025, staff built upon the outreach and engagement efforts of the SWSP, inviting all residents and property owners within a 500-foot radius of the remaining TOC parcels to a neighborhood meeting at Cotati City Hall. Four people attended the meeting and several others called in to ask questions and voice their perspectives. Generally, interested individuals were supportive of the policy efforts to get more homes constructed and to generate more business activity, but were concerned about parking impacts that could result from these intensified business activities (given the inability of the City to require any parking minimums under the proposed policies). On September 15, 2025, the Planning Commission considered the strategy and code changes proposed by staff to implement the TOC policy at a workshop. After receiving the staff report and presentation, the Commission discussed the proposed policy changes and voted unanimously to support the staff recommendation, making a few additional recommendations. Specifically, the Commission recommended that the City Council incorporate a micro-distillery land use and ensure vintage clothing stores are permissible in the CMC. On September 23, 2025, the City Council received the Planning Commission recommendation regarding the strategy and code changes proposed by staff to implement TOC policy and make other proposed Cotati Municipal Code (CMC) revisions, also through a workshop format. After receiving the staff report and presentation, the Council discussed the proposed policy changes and voted unanimously to support the staff recommendation, including the Commission recommendation to incorporate micro-distillery and vintage clothing land uses into the CMC, including in the TOC area. On November 3, 2025, the Planning Commission held a public hearing to consider a draft ordinance to implement comprehensive set of code amendments to comply with the ABAG/MTC TOC policies as well as make some modifications to the CMC to resolve identified challenges and to implement policy direction received from the Planning Commission and City Council. After considering the ordinance and receiving the public comment, the Commission voted 2-1 to recommend that the City Council introduce the ordinance. Additional details on the Planning Commission consideration are provided below.

OBAG Funding and Eligibility Future OBAG funding cycles will consider funding revisions that prioritize investments in transit station areas that are subject to and compliant with the TOC Policy. To ensure eligibility for OBAG 4 funding and any other discretionary funding that may be linked to TOC Policy compliance, jurisdictions are being directed to demonstrate compliance prior to adoption of OBAG 4 (expected in 2026). Compliance with TOC policies is anticipated to be measured on a 100-point framework equally measured (25 points each) across four categories:

Density, Housing, Parking, and Station Access. These categories are further divided into specific standards, each of which is assigned a numeric point value. As proposed, staff anticipates the proposed changes will result in the City being near full compliance with TOC policies. The identified areas of “scoring weakness” are primarily around the Access Gap Analysis (8 points) and Mobility Hub Planning (7 points) required for the Station Access component of TOC compliance primarily due to this analysis being done as part of the SWSP, which was drafted and approved before the TOC policy guidance was completed by ABAG/MTC. See the attached ABAG/MTC compliance slideshow for more details on compliance scoring.

Analysis/Discussion
Land Use and Planning Considerations
TOC Policy Summary
As discussed during the workshop and identified above, TOC policy implementation and compliance is divided into four categories: residential and commercial density; housing (production, preservation, protection, and business stabilization); parking; and transit access. To be deemed compliant jurisdictions must implement several policies in each of these categories with thresholds based on available transit “tiers.” These tiers are defined by the scale, frequency and intensity of the transit availability in each jurisdiction, with Cotati (and all north bay jurisdictions) being categorized as “Tier 4’. Some standards are specifically required (residential and commercial density) while others may be selected from a menu of policy options. For the latter, ABAG/MTC allows jurisdictions to choose from a provided list of policies within each category as a means of achieving TOC compliance.

During the workshop, staff presented the entire menu of available policy options, and highlighted a recommended choice for each category based on established Council Goals, commitments in the Housing Element, state law requirements and other identified department priorities. Below, staff has provided a summary of the TOC compliance requirements, the policy direction recommended by the Planning Commission and selected by the City Council and a summary of the code changes or other implementation mechanisms proposed to achieve the TOC policy.

1. Zoning and Land Use
-Minimum density zoning near transit: Tier 4 jurisdictions must allow 25-35 units per acre of residential and mixed-use development and a commercial Floor Area Ratio (FAR) of 1.0-3.0. -Reduced parking requirements: Tier 4 jurisdictions must eliminate minimum parking requirements and implement a maximum of 1.5 parking spaces per residential unit and 1 space per 250 square feet of commercial square footage.
-Require one secured bicycle parking space per residential unit and one secured space per 5,000 square feet of commercial office land uses.

Staff Response: Staff has created two new zoning districts for inclusion in the CMC. The first is the Santero Way (SW) zoning district proposed for the developed parcels on Santero Way and the remaining un-developed and under-developed properties south of these existing homes. The second is the Transit Oriented Communities (TOC) zoning district proposed for the undeveloped and under-developed parcels north of the existing homes on Santero Way, and all of the other TOC eligible parcels with frontage on E. Cotati Avenue. See SW and TOC Parcel ID Map, attached.

2. Affordable Housing and Commercial Stabilization
As discussed and presented during the workshop, TOC Policy requires a jurisdictions to adopt at least six housing policies, selected from a menu of 26 pre-determined strategies identified by ABAG/MTC. Jurisdictions must select at least two policies for each of the “3Ps” of Housing:
affordable housing production, preservation, and protection. Additionally, jurisdictions must select at least one commercial stabilization policy from a menu of four options. Below, staff have identified the policies supported by the Planning Commission and City Council for adoption, including a statement of clarifying information and a summary of the proposed compliance methodology. Appendix A of the attached MTC Administrative Guidance document (May 2025, Version 1.1) includes additional information on each of the strategies, as referenced in the discussion below.

Production (at least 2 required)
Production Policy 4- Public Land for Affordable Housing. Development of 120 E. Cotati Ave with 100% affordable housing project is proposed to satisfy this compliance element of the ABAG/MTC TOC policy (see Appendix A of MTC Admin Guidance pg. 9-10 for compliance details).

Production Policy 6-Streamlined Entitlement Processes. This ABAG MTC TOC policy language directs the City to match/implement the SB 330 vesting rights and “no net loss” provisions (see Appendix A of MTC Admin Guidance pg. 17-18 for compliance details). See CMC redline Sections 17.30.082; 17.60.070; and 17.64.080, for proposed implementation language (redline attached).

Preservation (at least 2 required)
Preservation Policy 4-Condominium Conversion Restrictions. Require that units converted to condominiums be replaced 1:1 with comparable rental units, unless purchased by current longterm tenants or converted to permanently affordable housing with protections for existing Tenants (see Appendix A of MTC Admin Guidance pg. 24-25 for compliance details).

Implements HE Program 4-1. See CMC redline Sections 17.30.082 Preservation Policy 7-Mobile Home Preservation. Policy or program to preserve mobile homes from conversion to other uses that may result in displacement of existing residents (see Appendix A of MTC Admin Guidance pg. 31-32 for compliance details). Existing CMC mobile home park regulations adequate. Implements HE Program 1-6
Protection (at least 2 required)
Protection Policy 2-No net Loss and Right to Return to Demolished Homes. Require one-to-one replacement of units that applies the same or a deeper level of affordability, the same number of bedrooms and bathrooms, and comparable square footage to the units demolished. Provide displaced tenants with right of first refusal to rent new comparable units at the same rent as demolished units (see Appendix A of MTC Admin Guidance pg. 37-38 for compliance details). See CMC redline Sections 17.30.082 for proposed implementation language (redline attached).

Protection Policy 6-Rent Stabilization. Restricts annual rent increases based upon a measure of inflation or other metric, with provisions exceeding those established by AB 1482 (2019, Chiu). Cotati’s existing mobile home park rent stabilization code may be adequate to comply. AS this is yet to be determined staff has proposed three protection policies as a means to comply.

Protection Policy 7-Previenting Displacement from Substandard Conditions Associated with Code Enforcement Activities. Policies, programs, or procedures designed to minimize the risk of displacement caused by substandard conditions including through local code enforcement activities (see Appendix A of MTC Admin Guidance pg. 48-50 for compliance details). Implements HE Program 4-5.

Commercial Stabilization (at least 1 required)
Commercial Stabilization Policy 4-Small Business Advocate Offices. Provide a single point of contact for small business owners and/or a small business alliance (see Appendix A of MTC Admin Guidance pg. 60-61 for compliance details). City staff have updated the Community Development (CD) Department webpage to implement and advertise a “Business Liaison” program whereby business can contact the City and have a staff member assigned to assist them with identified challenges and concerns. This new program is also consistent with and implements the FY 2025-26 CD Work Plan.

3. Parking Management (all policies must be implemented in the TOC areas) ABAG/MTC TOC Policy mandates eight parking management elements within the ½ mile TOC area. Current City of Cotati parking policies are not fully aligned with the TOC Policy and staff have drafted municipal code updates to bring the City’s current parking policies into TOC conformance (see attached draft redline amendments). It is notable that the recommended reduced parking ratios are proposed to be adopted for the TOC policy area (1/2 mile surrounding the SMART station) only, while some of the more general parking standards and policies are recommended for citywide adoption. This is intended to both support compliance with the TOC policies and to facilitate parking management in light of state-mandated reduced parking requirements. Below is a summary of the required TOC parking policies and the areas of the City the these proposed code revisions would apply to.

Requirement Response
Residential Parking Minimums Proposed in TOC: 0 spaces per unit Residential Parking Maximums Proposed in TOC: 1.5 spaces per unit Commercial Parking Minimums Proposed in TOC: 0 spaces per sq ft Commercial Parking Maximums Proposed in TOC: 4 spaces/1000 sq ft Allow Shared Parking Between Different Land Uses Current Codes Consistent Allow Unbundled Parking (Separate the Cost of a
Parking Space from Rent/Sales Price)
Proposed City-wide (CMC 17.26.040)
Residential Bicycle Parking: 1 Secure Space per
Unit
Proposed City-wide (CMC 17.36.070)
Office Bicycle Parking: 1 secure Space per 5,000
Occupied sq. ft.

Proposed City-wide (CMC 17.36.070)
In addition to the policy changes referenced above and similar to the housing policy options discussed, the TOC Policy requires adoption of one complementary parking management strategy for the TOC area, selected from a menu of options. The staff recommendation to meet the TOC compliance requirements is highlighted.

Complementary Policies for Parking Management
Policy 2-Curb Strategy/Management. Create priority for curb access based on variable needs. In the era of reduced parking requirements, mobile delivery services, multimodal transportation options and the continued (partial) reliance on automobile trips, demand for curb space is ever increasing. Given this increasing demand, directing that infrastructure to serve each of the users of the curb space be built into future developments is seen by staff as critical to ensuring functional circulation around the City. See CMC redline Sections 17.39.030 G. 8., for proposed implementation language (redline attached).

4. Station Access and Circulation
The ABAG/MTC TOC Policy includes four strategies related to station access and circulation.

As summarized below, Cotati is partially compliant with the TOC access and circulation requirements with existing policies (such as the City’s past commitments to complete streets and the SMART station gap analysis completed with the SWSP Update) however, staff is recommending additional zoning changes to implement mobility hub elements into multi-family and mixed-use developments (see CMC 17.39.030 G. 9. in the attached redline code changes). If adopted, these changes should complete the City’s needed station access and circulation requirements for ABAG/MTC TOC policy implementation. These policy changes are intended to increase access to transit while supporting sustainable transportation options.

Requirement Response
Adopt a jurisdiction-wide Complete Streets Policy Compliant since OBAG 2 Prioritize implementation of active transportation projects in TOC area(s)
See future CIP Project List
and Project COAs
Complete an access gap analysis and capital improvement program for station access
Included in SWSP Update
and ATP
Identify Mobility Hub planning and implementation opportunities in TOC area(s)
Zoning Changes proposed
City-wide (CMC 17.39.030
G. 9.)

5. Recommended Compliance Pathways
ABAG/MTC have identified multiple pathways for jurisdictions to demonstrate TOC policy compliance including adoption of a TOC overlay zone; certification of a TOC-compliant Specific Plan or General Plan update; and/or project-by-project review and approval under TOC criteria. As summarized above, City of Cotati compliance methodology is proposed to be achieved through a combination of funding expenditures, adopted revisions to the CMC, and administrative programs intended to implement the policy direction. Primarily, compliance will be achieved through code changes proposed to the TOC 1/2-mile radius and more broadly the entire city (where appropriate and beneficial). The City purchase and development of 120 E.

Cotati Avenue is proposed to meet the production requirement given that the funding amount is adequate and identified plans meet the TOC policy requirements. Lastly, administrative commitments to department programs and policy implementation are proposed to meet the requirements regarding commercial stabilization and tenant protections.

To formulate the recommendations above, staff compared the TOC policy direction with the adopted Council goals, budget availably, in-progress/pending City commitments, and state law mandates. This analysis resulted in a recommended compliance approach that (staff finds) will achieve substantial compliance with the TOC policy direction while also meeting the adopted budget and policy goals identified by the City Council and established state legislation. In some instances where benefits from the updated policies are anticipated to address challenges beyond the TOC boundary or can be implemented with existing policy, staff has recommended these be adopted city-wide to facilitate implementation.

Additional Code Clean Up
Occasionally staff identify challenges with code implementation based on missing, unclear, or inconsistent language within the Cotati Municipal Code (CMC). Along with the TOC ordinance changes, staff is also proposing to address several of these identified issues including to recategorize “Tattoo and body piercing services” from the ‘personal services-restricted’ land use category, to the ‘personal services’ land use; to add Retail Tobacco Store into the land use tables and definitions; and to codify the process to amend the General Plan and/or Zoning policies of the City. Below staff has provided additional details on these elements of the proposed ordinance.

Tattoo and Body Piercing-If supported, this change would greatly expand the allowable locations tattoo artists may operate from within the City. Currently personal services-restricted categorizes tattoo businesses similarly to palm readers and pawn shops, limiting these uses to the CE zoning district and only in second floor and secondary (non-visible) locations. This classification effectively prohibits tattoo businesses from operating in other commercial areas of the city such as downtown and along the Gravenstein Hwy corridor. If changed to personal services, tattoo studios would be viewed more like a salon or esthetician and would be allowed as permitted land uses in all commercial areas of Cotati. The current classification has limited several new businesses from opening in Cotati, and the tattoo studio use is much more mainstream than it has historically been viewed, leading staff to propose this change for consideration.

Retail Tobacco Store- Retail tobacco stores (aka “smoke shops”) are not permitted at any locations within the City of Cotati. The two in operation were previously authorized and are “non-conforming” because the use is no longer permitted. The Chapter 17 (Land Use) of the CMC utilizes “permissive” zoning, meaning if a use is not listed, it is deemed to be not permitted. Additionally, the regulations governing tobacco retailers are included in Chapter 9 Public Peace, Safety and Morals of the CMC. This combination often creates confusion with project applicants and other parties interested in tobacco related land uses. To address this and clarify that retail tobacco stores are prohibited in Cotati, staff is proposing to update the code to list this land use, include its definition and clearly identify it as not permitted within Cotati.

Codified Amendment Process-Table 6-1 of the CMC identifies the decisions making process required for the City and/or project applicants to make “amendments” to the City’s General Plan and/or zoning policies. However, no process is included in the CMC describing the steps required to review and process such changes, or the findings required by decision makers to support any request to make such an amendment. In response to this deficiency, staff have drafted a codified process and findings to guide such future decisions. Given the significance of such potential future changes, it is important to have a defined process by which staff, the community and the decision makers of the City can look to for guidance in making such decisions. See Chapter 17.62.070 Amendments for details on this proposed CMC update.

Planning Commission Direction
During the November 3, 2025, public hearing to consider the proposed TOC implementation options, the Planning Commission indicated general support for the staff recommendations, both regarding TOC policy implementation and the proposed “clean up” changes. After receiving the presentation on the proposal. asking questions to ensure complete understanding and taking public comment, all members of the Commission were supportive of the proposed CMC amendments with one exception, Parking Unbundling. Members of the public and one commissioner voiced concerns that the unbundling of parking spaces from residential units would result in overall rent increases due to parking being identified as an “added amenity” but automobiles still be relatively necessary given the lack of adequate public transportation options.

Additional concerns were voiced that this change would disproportionately impact lower income residents and create parking impacts on surrounding residents and neighbors.

In response to this concern, the supporting members of the Planning Commission recommended that any unbundling be limited to only the TOC area, and that staff provide the City Council with information regarding the compliance scoring impacts of not including unbundled parking in the ordinance and also the potential costs of a parking space if charged separately from the rent.

Staff response: As identified in the MTC_TOC Evaluation Criteria (attached) unbundled parking is only identified as providing 1 point out of 100 for compliance scoring. Given this relatively minor impact on the score, and the challenges anticipated with enforcement of any unbundled parking mandate staff is not concerned with removing the unbundled parking from the TOC compliance ordinance.

An online search for available parking identified individual space pricing from $100-$150 per month for unsecured surface parking and $184-$500 per month for secured garage parking.

These prices were for spaces throughout the bay area and were not specific to Sonoma County.

IV. General Plan Consistency
These changes have been reviewed for compliance and consistency with the Cotati General Plan, including the Housing Element. Staff analysis has identified the following General Plan policies and actions as supporting the proposed changes to the municipal code and other policy implementation strategies:

Program 1-8: Residential Building Decarbonization: Continue to permit and encourage mixed uses and higher densities on in-fill and vacant sites in Priority Development Areas (PDAs) with public serving facilities, such as medical clinics, schools, and grocery stores, to discourage sprawl and encourage short vehicle trips and/or alternative forms of transportation.

Policy H-2.3 While the City is able to accommodate its share of the regional housing need without rezoning during the current Housing Element period, to the extent necessary, the City will consider land use re-designation and promotion of existing innovations like the Cottage Housing Ordinance in order to accommodate development capacity that affirm all other goals of the City’s General Plan and maintain Cotati’s rural character.

Policy H-2.6 Encourage mixed use development, including residential and live/work uses in commercial and office areas where the viability of the nonresidential activities would not be adversely affected.

Policy H-2.11 Encourage housing development on existing infill sites in order to efficiently utilize existing infrastructure.

In addition, these amendments are consistent with and implement the following General Plan policies and programs:

Policy CON 2.1: Improve air quality through continuing to require a compact development pattern that focuses growth in and around existing urbanized areas, locating new housing near places of employment, encouraging alternative modes of transportation, and requiring projects to mitigate significant air quality impacts.

Policy CON 3.10: Ensure that the layout and design of new development and significant remodels encourages the use of transportation modes other than automobiles and trucks.

Policy LU 1.1: Maintain a supply of developable mixed-use, commercial, industrial, and residential lands sufficient to meet desired growth and economic needs over the planning period.

Policy LU 2.5: Locate medium and higher density housing within easy walking or bicycling distance of public facilities, services, transit, and major employers.

Policy LU 2.10: Encourage mixed-use, pedestrian-, and transit-oriented development, with a focus on the Hub and major corridors.

Staff response: The proposed amendments will help to further the established goals, policies, and implementation programs of the General Plan, including the Housing Element and Santero Way Specific Plan to reduce greenhouse gas production and improve air quality by providing additional opportunities for alternative transportation and walkability; will maintain the supply of developable land and expand housing opportunities through increased density and increased development certainty, including on infill sites along E. Cotati Avenue and Santero Way; will direct that the layout and design of new development encourages the use of alternative transportation; will conserve resources by encouraging the efficient use of land and allowing more intense development of both residential and commercial land uses; and use land appropriately by increasing the intensity of development in close proximity to the train station and along one of the City’s primary commercial corridors.

Financial Considerations
Other than the staff time required to conduct the analysis and present the information, no direct financial impacts to the general fund were identified resulting from the analysis of TOC policy compliance. However, as has been identified, OBAG funding eligibility is being updated to include TOC compliance as a critical factor in fund allocation and grant approval. Given that a significant portion of the City’s capital improvement plan (CIP) budget has historically been funded by matching OBAG funds, a lack of compliance with TOC policy could directly impact the City’s ability to fund future CIP projects. Additionally, a strong TOC compliance score could allow the City to increase its competitiveness for these funds and receive additional funding.

Because ABAG/MTC is still finalizing the TOC compliance criteria, the scope and benefit of this additional competitiveness is undetermined.

Environmental Issues
In keeping with CEQA Guidelines Section 15168(a), a Program Environmental Impact Report (PEIR) was prepared to analyze and evaluate the environmental impacts associated with the Santero Way Specific Plan Update and implementation of the Transit Oriented Communities (TOC) zoning updates. In accordance with CEQA Guidelines Section 15094(d), after the City Council approved adoption of the Specific Plan Update, the city filed a Notice of Determination with the County Clerk. Following adoption of the updated SWSP, proposed development projects that are consistent with the Specific Plan would undergo a streamlined CEQA review process. The proposal to adopt an ordinance implementing the TOC policies is seen as consistent with the EIR analysis and determination, as well as the environmental impact analysis of the Cotati General Plan EIR.

Both of these complete EIR (draft and Final) documents and all appendices are available for public review on the City website. These documents include impact analysis across all categories analyzed under CEQA; all comments received throughout the process and responses to each; summary of impacts all mitigation measures identified to mitigate to less than significant impacts.

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