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May 6, 2021 <br />Page 2 <br /> <br /> <br />5005-003acp <br /> <br /> printed on recycled paper <br />Number (“APN”) 77-447-14-6, 77-447-7-1, 77-447-14-7, 77-447-15-6. The Project is <br />located in the DA-1(S), Downtown Area 1 (Special Policy Area 3) zoning district. <br />The anticipated construction schedule assumes that the Project would be built over <br />a 20-month period.2 Required Project approvals include a Conditional Use Permit <br />(“CUP”) and Site Plan Review, a Parking Exception, and approval of a CEQA <br />document for this Project. <br /> <br /> The Checklist evaluates the Project’s potential environmental impacts and <br />consistency with the City’s 2035 General Plan Update Final Environmental Impact <br />Report (“GP EIR”) and the 2007 Downtown San Leandro Transit-Oriented <br />Development Strategy EIR (“TOD EIR”). We reviewed the Checklist and Staff <br />Report for the Project in conjunction with our technical consultants, and have <br />identified a number of significant deficiencies in the City’s analysis, as well as new <br />and more severe impacts than previously analyzed in the GP EIR and the TOD EIR. <br />Specifically, the Checklist fails to accurately analyze the Project’s construction and <br />operational air quality emissions as well as the public health risks to the <br />surrounding community from exposure to toxic air contaminants (“TACs”) <br />generated by the Project, which are new or more severe than previously analyzed. <br />Further, cumulative noise and greenhouse gas (“GHG”) emissions were not <br />accurately analyzed. Therefore, the City lacks substantial evidence to support the <br />conclusions in its Checklist and an Infill Environmental Impact Report (“EIR”) is <br />required. <br /> <br /> We reviewed the Checklist and Staff Report for the May 6, 2021 Planning <br />Commission / Board of Zoning Adjustments hearing (“Staff Report”) and prepared <br />our comments on air quality, public health, and GHG emissions with the assistance <br />of air quality and GHG expert Paul E. Rosenfeld, Ph.D. and hazardous materials <br />expert Matt Hagemann, P.G., C.Hg of Soil Water Air Protection Enterprises, whose <br />comments are included in the SWAPE Comments (“SWAPE Comments”). The <br />SWAPE Comments, Dr. Rosenfeld’s and Mr. Hagemann’s expert curriculum vitae <br />(“CV”) are attached hereto as Exhibit A. We have prepared our comments on <br />traffic and transportation with the assistance of Daniel T. Smith, Jr., P.E., principal <br />at Smith Engineering & Management. The Smith Comments (“Smith Comments”) <br />and Mr. Smith’s CV are attached hereto as Exhibit B. We have prepared our <br />comments on noise impacts with the assistance of Deborah Jue, acoustics, noise and <br />vibration expert of Wilson Ihrig. The Wilson Ihrig Comments (“Wilson Ihrig <br />Comments”) and Ms. Jue’s CV are attached hereto as Exhibit C. The attached <br /> <br />2 Checklist p. 4-38. <br />92