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7A Page 1 00 Page 34: Hattached "duet" homes (two units attached, different owners), or multi..family(three or more units attached, either single of multiple owners)." This is a statement with omissions. The Initial Study should specify "duet" as a new permitted use. This is a statement that Is ambiguous. The "duer' description seems to imply existing duplex lots can be converted to "duets". In other words, a "duet" can be built on minimum lot size of 7,500 sq ft. But, the actual Zoning Ordinance revision does not mention Hduet". Will the City Staff be creating a hon- codified interpretation for "duer'? Page 34: nEach alternative would permit .... multi-family (three or more units attached or detached, either single or multiple owners)." This is a statement With omissions. The Initial Study should specify apartments and condos as a new permitted use. Page 34: "All three scenarios have been analV1ed and, based on this analysis, the City has determIned that the proposed ordinance amendment is not expected to result in or allow new development in excess of what the City would expect under the existing ordinance." This is a false statement as detailed in the ILLEGAL PAST PRACTICE section. The 2004 Housing Element clearly limits the maximum density for the three permitted dwelling buildings In R2: 8.7 units/acre for single family, 11.6 units/acre for duplex, 12.9 units/acre for tri'plex. The recommended density change would increase density to 17.4 units/acre for all three permitted dwelling buildings. 17.4 units/acre exceeds the General Plan density Iimft for R2. 17.4 units/acre is a significant Increase' in the permitted density . Page 34: /llf any of the three options is approved, the amendment would either permit less dense development than the City would anticipate under its eXisting intt!rpretation of the ordinance and its existing practice with respect to its implementation of the existing ordinance, or an equal amount of development; in no event, however, would the Oty expect the proposed amehdment to allow more dense development of lots larger than 10,000 square feet. II This Is a false statement as detailed in the ILLEGAL PAST PRACTICE section. Page 34: "The project does not have the potential to degrade the quality of the environment" ThIs Is Is a false statement, if environment Includes traffic, off-site parking, noise, and character neighborhood. There has been no traffic impact analysis to make such a claim. Other than the off-site parking Impact analysis associated with the Kentfield project in' 2009, there has been no off-site parking 26