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The Honorable Mayor Diane Howard/City Council <br />Page 5 <br />August 7, 2020 <br />would be inconsistent with the City's General Plan. It would also be highly questionable from <br />a land use planning standpoint, given the sensitivity of this use juxtaposed against the light, <br />noise, odors and traffic invariably associated with heavy industrial uses. This appears to be a <br />textbook case of incompatible land uses. <br />Under CEQA, the consequence of proposing such incompatible land uses side by side is clear: <br />a project which proposes a land use which is incompatible with a community's General Plan is <br />a potentially significant land use impact under Section 15125(d) of the CEQA Guidelines, <br />which must be analyzed and mitigated if feasible to a level of insignificance. <br />Therefore, because the "reasonably foreseeable" relocation of the Maple Street Shelter to <br />industrial property at 1402 Maple Street is a potentially significant land use impact under <br />CEQA, this impact must be analyzed and mitigated if feasible. Because the original 1548 Maple <br />Street EIR did not do so, and the Addendum, incorrectly, chose not to do so, the City must insist <br />that this analysis occur before the Project can be approved by the City, not only to comply with <br />CEQA, but to provide the public with meaningful opportunity to review and provide input into <br />how the City's property at 1402 Maple Street should be utilized. And, because relocating the <br />shelter would constitute a significant environmental impact not analyzed in any prior CEQA <br />documentation, a Supplemental EIR must be prepared for the Project under Section 15164 of <br />the CEQA Guidelines, and not an Addendum.' <br />The City Should Also Carefully Examine the Land Use Implications of the Proposed Land <br />Exchange Agreement <br />CEQA aside, Graniterock also requests that the City keep in mind that its property at 1402 <br />Maple Street has long been considered an important cornerstone piece of the City's industrial, <br />Port -serving area. Not only is this property designated for industrial uses under the General <br />Plan, it was also the subject of the Inner Harbor planning process and various other proposals <br />for possible development. We understand the haste of the County's approval of the Project, to <br />attempt to secure vital funding for support services, but, before the City conveys the 1402 Maple <br />Street site away, the Redwood City community, including the business stakeholders within <br />City's Port area, should have a chance to weigh in. <br />We should also point out that, if the City conveys the 1402 Maple Street property to the County, <br />the County will presumably take the position that the property would be exempt from the City's <br />land use planning laws, including the General Plan, under Government Code Section 53090 et <br />seq. The City and community may therefore lose any meaningful opportunity to participate in <br />the vision for this important property. We urge the City Council to take the time needed to <br />ensure that the City's priorities and the community are best served by the Project. <br />3 A Supplemental EIR, and not an Addendum is required because, at a minimum, the Project proposes a "reasonably <br />foreseeable" land use which is inconsistent with the City's General Plan, and which is, itself, a potentially significant <br />environmental impact requiring analysis. There may be other impacts associated with moving the Maple Street <br />Shelter, in addition to this land use impact, which require analysis under CEQA, including potential traffic, air, noise <br />and, given the location of the site, biological or other environmental impacts. It is not currently known whether any <br />other such impacts would be presented by the relocation, because the Addendum fails to study the relocation. <br />