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development project. They include but are not limited to general and specific plan adoptions or amendments, zong, use permit, variance, subdivision, building permit approvals, and execution of s roper y development fees can mrange The examples of dedication payment drainage, from the standard ones such as streets, sewers, parks, offsite improvements to the payment of fees for the building of child day care centers in commercial developments, for public art, for the financing of a municipal railway system, providingfor (substations a d arate fire income housing, library sites, police stations. In J.W. Jones Co. v.. City of San Die o, 157 Cal. App. 3d 745 (1984), the court ruled t San benefits ° could use assessment its police power to impose facilities ("FBA") on developers " in order in the ry generut its al plan"gaferal the development scheme as sketched i g al City. An FBA would require the installation of a broad spectrum of public improvements by the developer such normally public the past financed by general city revenues libraries and fire stations. B. The General plan. The city under the umbrella of its police power can look to its zoning ordinance, subdivision ordinance, and use permit provision for many of the citard types of ies on the dedications. However, now more are general plan or applicable �ince� icplan isthe support dedication requirements. the general constitution for development, as *atop f the hierarchy of interpreted by the courts in California and since it i local government law regulating land usee" Neighborhood u V. Count of Calaveras, 156 Cal. 1� pe 3d 1179 Action Group ,„r,_ - (19 de cation Trements can flow from these goals and policies contained in such plans. J. W. Jones Co. V. Cit of �tet ie go,� sutra. Since all land use approvalmust onsisnt�-eh the -goads, policies and objectives of the general plan, conditions can be attached to achieve these goals. In 5oderlial v. city ofSanta Monica, 142 Cal. App. 3d 501 19�3) t� court, in ►o the city's requirement that smoke detectors be installed in all units in a condominium conversion without any specific ordinance or regulation on its books relied safenhousi 9objectives all:�f the The city's general plan "to promote court said such a condition was valid to achieve the goals of the city,"s general plan and the power to impose the some especially in the subdivision field nce need not be or promulgationeofba the specific enactment of an ordinance F regulation. _25_