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<br />~ <br /> <br />'"l <br />AnlCMMEIT _J <br /> <br />78 <br />Page 23 <br /> <br />MIL1.ER STARR <br />REGALIA <br /> <br />1331 N. California B1",d. <br />Fifth Aoor <br />Walnut Creek. CA 94596 <br /> <br />T 925 935 9400 <br />F 925 933 4'26 <br />www;msr1eglll.com <br /> <br />February 26, 2008 <br /> <br />\D)\E~~~~~\R\ <br />l~ru FEB 2 6 2008 \JlJ <br />CITY OF REDWOOD CITY <br />CITY CLERK <br /> <br />Robia S. Chang <br />RSCCmsrlegal.com <br />925941 3214 <br /> <br />VIA HAND DELIVERY <br /> <br />Honorable Mayor Foust and <br />Members of the City Council <br />City of Redwood City <br />1017 Middlefield Road <br />Redwood City, CA 94063 <br /> <br />Re: Notice of Appeal; February 19, 2008 Planning Commission Decision on <br />San Mateo County Community College District Application for Planned <br />Development Permit <br /> <br />Honorable Mayor Foust and Members of the City Council: <br /> <br />Our firm represents the Woodhill Estates Homeowners Association, an association <br />of 68 homeowners residing approximately a quarter-mile downhill from the proposed <br />site for the San Mateo County Community College District's C'District") Canada <br />College Faculty/Staff Housin-g Project, a 60-unit reSidential housing project <br />("Project"). Pursuant to Redwood City Municipal Code Section 48.1, we are <br />submitting this letter on behalf of our client, as formal written notice of appeal of the <br />February 19, 2008 decision of the Redwood City Planning Commission <br />(~Commission") to approve the District's application for a Planned Development <br />Permit ("Development Permif). <br /> <br />In sum. the City's approval of the Development Permit is an invalid exercise of the <br />City's police power because the project site is entirely within the corporate <br />boundaries of the Town of Woodside ("Woodside"). The City cannot approve the <br />Development Permit unless and until the San Mateo County Local Agency <br />Formation Commission ("LAFCO") approves the detachment from Woodside. In <br />addition, the Addendum prepared by the City does not satisfy the requirements of <br />the California Environmental Quality Act. Public Resources Code Section 21000, et <br />seq. ("CEQA") because neither the Addendum, nor the Mitigated Negative <br />Declaration ("MND") previously prepared by the District, adequately identifies and <br />analyzes all of the impacts of the project with respect to the approvals that must be <br />granted by the City of Redwood City (general plan amendment and pre-zoning). As <br />discussed below, the City must prepare a Subsequent MND or environmental <br />impact report ("EIRH). <br /> <br />Offices: Walnut Creek I Palo Alto <br /> <br />WODH\48B17\ 727726.1 <br />