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<br />1'''''.1111 I V'VI'L.I\ L..1-1 <br /> <br />'....0 -.... ~....... ........-...._....... . ---/--- <br /> <br />RUTAN <br /> <br />~ ."TTOP:~~Y~ "'T 1./\"<<-" <br /> <br />Mayor and Members of the City Council of <br />the City of San Leandro <br />. August 29, 2007 <br />Page 4 <br /> <br />Population and Housing <br /> <br />. New jobs and increased population created by the TOD Strategy will increase the <br />demand for affordable housing in San Leandro. Unfortunately, San Leandro has not met <br />the affordable housing goals established in its latest Housing Element. To the extent that <br />the project will increase the demand for an already insufficient supply of affordable <br />housing, the project is inconsistent with the City's Housing Eiement and General Plan. <br />These effects should have been analyzed in the EIR. <br /> <br />. In addition, to the extent that the residential land uses are increasing beyond that <br />authorized in the City's General Plan, the City is required to demonstrate how the land <br />use element and the transportation element remain appropriately correlated. As this has <br />not been discussed in the Em, the EIR is flawed. <br /> <br />. According to the EIR, the TOD Strategy suggests that by 2015 there will be <br />724,767 square feet less of non-residential job generating land uses as a result of the <br />pr0ject, while resulting in a 439 more residential units than the total envisioned under the <br />General Plan. This is likely to create or exacerbate a significant jobslhousing imbalance, <br />the effects of which were not analyzed in the EIR. <br /> <br />. Comments submitted by the organization known as COR, dated July 19, 2007, <br />which were included in the Final EIR, are incorporated by reference into this letter. <br /> <br />Public Services <br /> <br />. As noted in the EIR, the TOD Strategy would intensify the density of <br />development within the TOD Strategy Area, adding approximately 3,431 new residential <br />units with an estimated population of 8,749 people, approximately 718,240 square feet of <br />office and 120,870 square feet of retail space over the next 20 years, and could adversely <br />affect the provision of fire and police services. The EIR essentially concludes that the <br />overall impacts are too speculative, and that as a result the impacts are considered less <br />than significant. The EIR also indicates that the TOD strategy does not represent "an <br />actual project involving physical development," which appears at odds with the project <br />description of adding thousands of homes to the Strategy Area. The asserted speculative <br />nature of the impacts from the project does not justify, under CEQA, the conclusion that <br />associated impacts are considered less than significant. <br /> <br />. The EIR indicates that the project will add 639 new school students within the <br />strategy area, creating a project capacity deficit of 563 students. Page 4.10-21 indicates <br />that this project deficit of classroom space would be a significant impact. The EIR then <br />references Mitigation Measure PUB-I, which contains nothing more than goals and <br />policies, and. indicates that the significance after mitigation is "significant and <br />unavoidable." CEQA requires consideration and implementation of actual mitigation <br /> <br />2901023592-00 13 <br />839931.01 ,08129.'07 <br />