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7A Page 101 impact analysis. There has been no noise Impact analysis to make such a claim related to the new permitted uses of condos and apartments. And the impact to the character was completely dismissed. Page 34: '111e Initial Study has determined that any of the three scenarIos to be incorporated into the amendment, is in compliance with the applicable (and use policies and zoning requirements of the City of Redwood City as stated In the City's adopted General Plan and Zoning Ordinance and will not conflict with the land use pattern of the area nor surrounding areas!' This is a false statement as detailed 1n the IllEGAl PAST PRACTICE. The City's interpretation of R2 density does not comply with the General Plan and Zoning Ordinance. The current Zoning Ordinance does not allow apartments and condos in R2. The current Zoning Ordinance limits slngle..famlly density to 8.7 units per acre. Page 34: "the project will result in no potentially significant Impacts to the- sons, hydrology, drainage patterns, utilities, noise levels, and traffic circulation and parking standards of the R-2 zoning districts or surrounding land uses.'" This is a misleading statement. The purpose of an environmental review Is analyze environmental impacts. In this statement, the City i$ a$serting parking standards of the R-2 zoning are not impact. Analyzing an on-site parking standard cannot be substituted for a parking impact study. The parking impact study must include both on-site and off-site impact. Page 7 item #2 of the Initial Study dearly states, "2) AU answers must take account of the whole action involved, indudhlg off-site as well as on- site, cumulative and well as project-level, indirect as well as direct, and construction as well as operational Impacts." Without a parking impact study and traffic impact study, the Initial Study is not CEQA compliant. Without an accurate characterization of the expected increase In density (e.g. duplex conversion not included in analysis), no one can quantify the environmental impact. Page 34: ''The project does not have impacts that are individually limited, but cumulative considerable." This is a false Statement. The InitIal Study must account for cumulative impact of potential future development. For the Kentfleld project, the cumulative impact of off-site parking was significant. Without a parking impact study and traffic impact study, the Initial Study is not CEQA compliant. Without an'accurate characterization of the expected increase in density (e.g. duplex conversion not induded In analysis), no one can quantify the environmental impact. Page 34: ((Development would be limited to residential use, consistent with surrounding neighborhoods." 27