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<br />~Urban . <br />@X@Habltat <br /> <br />We are concerned that the proposed plan. ifimplemented in its current fonn, will result'in the City of <br />San Leandro's (henceforth ''the City") inability to meet the housing needs oflts residents and workforce <br />and result in further non-amlpliance with its RHNA allocation as well as a greater imbalance between <br />jobs and housing. Furthermore, we are concerned that the plan will lead to increased rents and condo <br />conversions ill the TOO area, resulting in gentrification and resident displacement. <br /> <br />This letter is broken into three parts; first, a section with our detallcd comments and seeond, a section <br />with a summary of our requested stuclies and third, a summary of mitigations to address many of the <br />anticipated adverse impacts. <br /> <br />1. Detailed Com.eats: <br /> <br />Commut 1: TOD Plan Does Not Meet City'. S..tect Affordable ROdial Obj.edvu or Recio". <br />Bou.IDg N..... AUoeatioll Req.irna...ts aad DEIR Does Not Add..... Tllese lacouistcaeia <br /> <br />CEQA Guiclelines, section 15 12S(d) requires that the "ElR shall discuss any i~nsistenc:;in between the <br />proposed project and applicable general plans and reaional plans. Such regional plana include. but are <br />not limited to, the applicable air quality attainment or maintenance plan... regional transportation plans, <br />regional housinaaUocation plans. .." By not doing so, the City's failure to address these inconsistencies <br />constituteS a violation of'CEQA's requirements as well ti denies the City and the public full information <br />needed to adequately assess the true impacts of a project or plan. <br /> <br />J. .. The City is sil"ifacantly out of compliance with meetine its ABAO/HCD Reaional Housing Needs <br />Assessment wletS for the period endln& in 2006. Between 1999 and 2006, no low-income units were <br />built and oftbe 108 very-low-income units built, the majority were for seniors and developmentally <br />disabled adults. Thus, the majority of very low-income units did not accommodate all ages or household <br />types, which directly contravenes the City's very own Ocornl Plan policies, partlclllarl)' General Plan <br />Policy 3.02. By the end of2006, the City was short on its RHNA by 87 vcry.low-income uniu and 107 <br />low-income units. <br /> <br />Table 9. BOM EI.....t N..... 999- <br />HouIcIaold Income eateaorY Houslnt ~ Goal HoutIaa <br />1999-2003 <br />V I't'1 Low 19S 101 <br />Lm 1m Q <br />SubtoIaI 302 101 <br />ModcnIte 251 lS8 <br />HIJh 317 961 <br />T01II .10 1227 <br />iource: City at SIA lAudro COIMlUftily DowIoplIIcN DlIIW..... (Ihlm 1Wm:I.D1I1IIl:III AI/tIfIt:y <br /> <br /> <br /> <br />As discussed below, the current affordable housing policies within the TOO Plan are insufficient to <br />'catch-lip' and provide for the needed units under Ihe 1999-2006 RHNA and will be insuffldent to meet <br />requirementS under the 2007.2014 RHNA, even based on the most c:ons.vative estimates that usume <br /> <br />a61'" Sb'eIt. S1IIte ua, 0I1cJ.... CA M612 <br />(nO) U9-9S1O . fax: ~ "","10 <br />www,~""bitat.oll <br /> <br />St/Sla ~d <br /> <br />llot.lIS\'H ~ <br /> <br />lat966EBlatS <br /> <br />6S:tt Llala~/~~/Bla <br />