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proposed development of 936 Marina Boulevard, if evaluated with the remainder of the project, would not result in identification of any new potentially significant impact not recognized in the IS/MND, would require no new mitigation measures not identified in the IS/MND, and would not result in the failure of mitigation measures identified in the IS/MND to reduce the impacts of the project to a less than significant level. CEQA Section § 15073.5 (c) (1-4) indicates that re-circulation of the IS/MND is not required when revisions to the project are added in response to written comments on the project's effects which do not introduce new avoidable significant effects or require new or changed mitigation measures. Therefore, even if development of the 936 Marina Boulevard site were included in the analysis for the proposed project, because it would not create a significant impact itself, contribute to a significant cumulative impact, or require different mitigation, re-circulation of the IS/MND is not required. Response to Comment A. 2. It is staff's opinion that the future development of the 936 Marina Boulevard site would qualify for exempt status as an in-fill project, identified as CEQA Section 15332. Further, staff believes that there is not a reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances. Due to planned widening of a portion of Marina Boulevard in the project vicinity, and based upon the proposed uses themselves, staff has not identified any significant cumulative effects from implementation of the three automobile dealerships. (Please see Response to Comment C below for further response with regards to transportation issues). The proposed concentration of automobile sales/service related uses is neither unusually high nor is it unanticipated, as characterized by the commentor. As early as the late1980s, this area, which included a mixture of automobile service, commercial and industrial uses was targeted for redevelopment as an automall. Land use intensities were identified in both the existing General Plan and proposed General Plan with this use in mind. To date, existing and proposed development proposals have fallen well within the maximum development intensities identified in the General Plan. The proposal for 936 Marina Boulevard also falls within the development parameters set forth by both the General Plan and Zoning Code. Development of this site would not result in a significant environment effect in and of itself, nor would it contribute to a significant cumulative impact when evaluated with the remainder of the project. Resnonse to Comment B. The commentors have criticized the mitigation measures for identified potentially significant impacts in the area of hydrology and water quality. The commentors assert that the mitigation defers analysis and imposition of particular mitigation measures. The mitigation measures that were identified on page 7 of the Initial Study should properly be recognized as mandatory conditions for project approval. Staff has concluded that imposition of these mandatory conditions of approval would ensure that any impacts in this area would be less than significant. Therefore, the mitigation measures criticized by the commenter are not required. However, as indicated above, the measures identified on page 7 of the Initial Study will be required as conditions of project approval. Similarly, the mitigation measures that were identified on page 5 of the Initial Study should properly be recognized as mandatory conditions of project approval. On the basis of geotechnical studies previously conducted for the site, staff has concluded that imposition of these mandatory conditions of approval would ensure that any impacts in this area would be less than significant. In addition, the mitigation measures that were identified on page 13 of the Initial Study should also be properly recognized as mandatory conditions for project approval. Staff has concluded that imposition of these mandatory conditions of approval would ensure that any impacts in this area would be less than significant.