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<br />" <br /> <br />Mayor Jack Grenalch <br />November 21/ 1989 <br />Page 3 <br /> <br />3. Enhancinq the Downtown Area's Commercial De~i~ability <br />Is Not A Proper Basis for Redevelopmen~. <br /> <br />When the principal objectives of a plan are to develop the <br />land profitably, bring in more private enterprise, raise land <br />values, and promote commercial and industrial development, <br />redevelopment is not justified. "[I]t is not sufficient merely <br />to show that the area is not being put to its optimum use, or <br />that the land is more valuable for other uses." ReguJLvs. city <br />of Baldwin Park (1977 ) 70 Cal. App. 3d 968/ 977-78, 139 Cal. <br />Rptr 196. <br /> <br />In contrast, the Report demonstrates that the Second <br />Amendment's primary purpose is to provide public improvements and <br />to increase the economic productivity of the Downtown area by <br />promoting commercial development that will increase city revenues <br />and jobs. <br /> <br />Consequently, redevelopment is not justified on this ground <br />as well. <br /> <br />4. The Second Amendment Does Not Further the Purposes <br />of Redevelopment Law. <br /> <br />The proposed use of redevelopment may be examined to <br />determine the validity of the Second Amendment. Sweetwater, <br />supra, ll8 Cal 3d at 28, fn. 6. A fundamental purpose of <br />redevelopment is to expand the supply of low and moderate income <br />housing and employment opportunities for the jobless, under- <br />employed and low income people. (~33071) A plan's failure to <br />specifically provide for the achievement of these purposes is <br />evidence that the project area is not in fact blighted, par- <br />ticularly when the proposed redevelopment is in reality a master <br />list of expensive public works projects, as they are in the case <br />of the Second Amendment. <br /> <br />In contrast to redevelopment's housing purposes, the FEIR <br />acknowledges that land use succession due to implementation of <br />the Second Amendment will set in motion low and moderate income <br />displacement. Since the proposed "mitigation" is so speculative <br />and uncertain, the net effect of the Second Amendment could be a <br />net loss of such housing. <br /> <br />Measures against the above legal principles, the project <br />area is not truly blighted and the proposed redevelopment <br />activities are not designated to fulfill the purposes of redevel- <br />opment. Instead, the Second Amendment seeks to enhance the <br />commercial desirability of an already productive Downtown area <br />and to increase revenues to the city. <br /> <br />13 <br /> <br />11191 <br />