The
Disneyland Area Zoning Plan is such that Disney cannot put timeshare units in via a stealth mode. To develop a new timeshare ownership resort or portion, lots of things have to be filed. To develop units as timeshare, the builder has to file typical floor plans for each unit, a construction phasing plan, management stuff, some general boilerplate stuff about the timeshare operation, a parking study, and how they plan to collect the transient occupancy tax. It's pretty substantive.
If anything, Disney might apply for the Conditional Use Permits to repurpose part of Paradise Pier or the Disneyland Hotel, but, again, it would be subject to approval by Anaheim. Similarly, an application to build a DVC-only resort would be subject to the zoning code (not just Disney's property, but everything within certain geographic borders). Per 18.114.050 of Anaheim zoning code, up to 150 units total can be timeshare/vacation ownership units. There are currently 71. So it would either be a really small development (and maybe hard to get blessing to build, since the area plan seeks out a certain level of density), or need to get blessing to be bigger.