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78 Page 28 Honorable Chair Tom Cronin and Members of the Planning Commission January 8, 2008 Page 2 Project. As you know, CEOA requires a Lead Agency (in this case, the District) to analyze the significant environmental effects of a project prior to its approval and to mitigate or address those effects where feasible. The basic purposes of CEQA are to (1) Inform governmental decision. makers and the public about the potential, significant environmental effects of proposed activities; (2) Identify the ways that environmental damage can be avoided or signIficantly reduced; (3) Prevent significant. avoidable damage to the environment by requiring changes in projects through the use of alternatives or feasible mitigation measures; and (4) Disclose to the public the reasons why a governmental agency approved the project in the manner the agency chose if significant environmental effects are involved. (14 Cal. Code Regs. i 15002.) A .projeer refers to the whole of an action and must encompass all components of the activity being approved. ('4 Cal. Code Regs. 9 15378.) Where the impacts reJevant to a project are covered in a previously prepared negative declaration, future environmental documents may build upon it. (14 Cal. Code Regs. S 15152, 15385.) Nonetheless, a responsible agency must comply with CEOA before making its decision. (See 14 Cal. Code Regs. ~ 15096(1) [A responsible agency must consider the environmental effects of the project as shown in the negative declaration prior to reaching its decision on a project.]; 14 CaI. Code Reg$.'~ 't5096(l'IJ[A .t!sliOnsi~lfnigeney cannot rely on the iead agencys findings and must make and adopt its own findings.).) Here, the MND does not analyze the impacts of the City's approval of the General Plan Amendment, pre.zoning and entitlements for the Project. For example, the Initial StUdy indicates that the Project will have no impact on Land Use and Planning and provides that the "proposed Redwood City zoning designation (R-3) for the project site would be consistent with the existing school designation because the housing would be an accessory use to the coliege." (Initial Study, p. 3-50.) The MND assumes the Project's consistency with the proposed zoning change but does not analyze the impacts of such change, which will aUow more Intense residential development than the current zoning designation allows. The City is required to conduct further environmental review and prepare a subsequent MND or EIR prior to its granting the necessary approvals. A proper environmental analysis of the Project will enable the City to develop appropriate mitigation measures that minimize potentially significant impacts, including those that give rise to the Association's concerns with the site plan and design of the Project. and additional impacts on aesthetics. noise, traffic, and safety. We will submit additional detailed comments describing the inadequacies of the MND and Addendum for the City Council's January 28, 2008 meeting. Second, the Association has concems that the proposed out-at-character size, height and location of the Project's residential structures, comprised of 60 residential units and approximately 66,000 square feet of building space. will negatively impact the views of the hillside from the surrounding community and the homeowners' privacy interests. At a minimum, the height of the proposed structures should not WOOIM68t7\1227$'i.1