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<br />7A <br />Page 99 <br /> <br />Page 29: 'rrhis increase is well within the development envelope for the R-2 district estabUshed by the <br />City's approved Genernl Plan." <br /> <br />This Is a false statement. The City's interpretation of R2 density is not consistent with 2004 HOU$ing <br />Element of the General Plan. <br /> <br />Page 30: "does not exceed the maxImum development that the City anticipates pursuant to its existing <br />interpretation of the R..2 density limits..." <br /> <br />This Is a misleading statement. The Initial Study should inform the publi'c that the legality of CitYs <br />interpretation has been challenged and may not be legal. <br /> <br />Page 31: liThe project would not cause an Increase in traffic that is substantial in relation to existing <br />traffic load and capacity of the street system." <br /> <br />There is Insuffldent Information to validate this statement. There is no traffic analysis. The density <br />impact analysis is not complete and not adequate. Unless there is some form of traffic analvsls, no one <br />can make this statement. A traffic impact study is required for this document to be CEQA compliant. <br /> <br />Page 31: "The project would not result In inadequate parking capacity because any new development <br />would be required to meet Its parking needs on-site." <br /> <br />This Is a false statement. A parktng'analvsls was provided for the Kentfleld project in 2009 that clearly <br />shows the minimum on-site parking requirements would not meet the Kentfleld project parking needs. <br />The analysis shows that for each unit in the Kenttield project, at least one off-site parking space would <br />be required. An off-site, parking Impact study is required for this document to be CEOA compliant. <br /> <br />Page 33: fl... does not 'exceed the amount of development anticipated In the General Plan ...N <br /> <br />This is a false statement. City Interpretation of R2 denSity exceeds density specified by 2004 Housing' <br />Element of General P1an. <br /> <br />Page 34: "The City has been permitting development projects on lots larger than 10,000 square feet in <br />the R-2 district for many decades, and determining the permitted density based on an interpretation of <br />existing ordinance." <br /> <br />This Is a misleading statement. The City's interpretation of R2 density Is new. Other than the Kentfleld <br />project in 2009, City Staff has provided no evidence the Clt(s InterpretatIon of R2 density has ever been <br />used. See the NOT CONSISTENT WITH PAST DEVELOPMENT section. <br /> <br />25 <br />