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7A Page 83 Element of General Plan) does not discuss how density is handled for projects that have more than three (3) units In them which is what this density interpretation Is all about." [Ms Jill Ekas, Planning Manager, June 1st 2009 City Council meeting] Not only does Ms E~s confirm density is specified in the General Plan for all of the R2 permitted uses, but Ms Ekas also confirms City's interpretation of R2 density is not related to the R2 permitted uses. If the City's interpretation of R2 density is not related to the R2 permitted uses, then one can conclude the City's interpretation of R2 density is for R2 non-permitted uses, and therefore, non-compliant the Zoning Ordinance. And again, the statement that the Oty's interpretation is R2 density Is compliant to the current. Zoning Ordinance Is FALSE. By state Law, Redwood City Is required to comply With Its Municipal Codes and Zoning Ordinances. The CIty's interpretation of R2 density is not compliant with the current Zoning Ordinance. Therefore, tJ1e City's Interpretation of HZ density is IUEGAL. Past application of the City's interpretation of R2 density, Is an ILLEGAL PAST PRACTICE. In.summary~ . The Initial Study statement that the Zoning Ordinance does not specify density standards for Jots greater than 101000 sq ft is FALSE. . The Initial Study statement that the City's interpretation of R2 density is compliant with the current Zoning Ordinance is FALSE. . By State Law, Redwood City Is required to comply with its Municipal Codes and Zoning Ordinances. Since, the City's interpretation of R2 density is not compliant with the current Zoning Ordinance~ the City's Interpretation of R2 density is ILlEGAL . Past use of the City's Interpretation of R2 density, is an ILLEGAL PAST PRACTICE. NO IMPLlEb DENSITY The Initial Study states the Zoning Ordinance implies density for large lots. From the page 2S of the Initial Study: "As such, city staff has made an interpretation for density limits on larger lots in the R2 zone ... related to the density Implied in the zoning code as it is written ..." [lnftlal Study: page 25] There Is not implied densIty for larger lots. There Is not hidden message in the Zoning Ordinance. In fa~, the Initial Study does not offer any facts to justify the claim of implied density. Where Is the implied density? The maximum density for each of the permitted uses is defined: . 8.7 single family dwellings / acre on a mfnimu'm lot size of S,OOO sq ft, and max one dwelling per lot. 9