AgdaPkt 2020-11-09 Joint SA PFA - Laserfiche WebLink

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Mayor Diane Howard Honorable City Council of Redwood City November 9, 2020 Page 2 contains conclusions and lacks analysis. There is also inadequate discussion of whether this Project, in combination with other projects approved or pending in Redwood City and Menlo Park, will generate enough students that there will no longer be capacity at Sequoia High School. Both the Draft and Final EIR also disregard and/or misconstrue the holding of Chawanakee Unified School District v. City of Madera (2011) 196 Cal.AppAth 1016, which expressly holds that payment of developer fees does not constitute full and complete mitigation for school - related impacts other than school overcrowding. Thus, the City's reliance on Government Code section 65995(h) is misplaced, and the EIR for the Project is required to analyze all 27 school - related impact areas listed in our August 19, 2019, and February 28, 2020, correspondence. These concerns are further fleshed out and analyzed in detail in our prior correspondence related to this Project, all of which is enclosed for your reference. It is our hope, as well as our client's, that the City will slow down this process so that the District's concerns can be addressed. We note that the developer and District have met at least once to discuss the above concerns, but that pandemic -related considerations have prevented further meetings or any resolution. We therefore request that, at a minimum, the City postpone approval of this Project and certification of the EIR until the developer's commitment to work with the District and address its concerns is formally memorialized. Schools are a vital part of the infrastructure of a community that cannot thrive without responsible planning by their local agency partners. The District understands and supports the desire for adequate housing, but there must be a corresponding desire to ensure adequate school capacity to serve the families who will reside in that housing. Sincerely, LOZANO SMITH 6 Harold M. Freiman HMF/gc Enclosures cc: Ms. Lindy Chan, Acting Planning Manager (lchan@redwoodcity.org) Crystal Leach, Interim Superintendent (cleach@seq.org)