CEQA Guidelines Section 15126.6(e)(3)(B) identifies that for a project other than a land use or regulatory plan, the no project alternative is the circumstance under which the project does not proceed, going on to state that the discussion should address "the environmental effects of the property remaining in its existing state against environmental effects which would occur if the project is approved. If disapproval of the project under consideration would result in predictable actions by others, such as the proposal of some other project, this "no project" consequence should be discussed."

I take this to mean that if it is likely that another development project would be proposed, the no project alternative should identify and address the potential development that would occur. This alternative should base the other potential development scenario on the existing land use and zoning designations on the project site, so I would anticipate some discretionary actions (tentative map approval, etc) would be appropriate for this alternative; however, a GPA would not be appropriate. The alternative should also consider the adequacy of infrastructure to serve the site - meaning that if a future project would require expansion of a water treatment facility, construction of a bypass, etc., it may not be reasonably forseeable so may not be appropriate for the no project alternative.