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7A Page 90 TRAFFIC AND PARKING ANALYSIS There is no Traffic and Parking impact anaJysis In the Initial Study. And since the density analysis is incomplete and inadequate, no accurate determination of the Traffl(: and Parking impact can be made. For the Kentfield project, mitigate was required for the expected impact of thfs one project. In addition, an off-site parking impact study clearly demonstrated that one can expect one additional car parked off-site for each unit in the project. For the 213 expected additional in-fill units about 4,000 ft of off-site parking may be required. And the 213 expected the addJtionalln-flll units do not indude the potential increase in family units if adjacent lots are combined to create larger lots that would qualify for the higher development density. The CEQA exemption is applicable to in-fill, therefore, an 'environmental review of future R2 development reJated to the.proposed Zoning Ordinance modification may 'not occur. The traffic and parking analysis as disclosed Is not complete and not adequate for determining the impact of this project. Therefore, the Initial Study Is not CEQA compliant. INITIAL STUDY I NEGATIVE DEClARACTION WALK-THRU This section identifies false statements, misleading statements, and statements not substantiated by facts presented in the Initial Study, nor referenced by other documents. Page 1: ttThe existing ordinance spedfles density standards for lots up to 10,000 square feet, but does not specify density standards for lots larger than 10,000 square feet/' This is a false statement. As documented in the IUEGAL PAST PRACfICE section, Article 6.10.B specifies maximum one dwelling building per lot. The Zoning Ordinance specifies density standards for all lot sizes and all permitted uses. Page 1: "The City has been applying its density standards for lots smaller than 10,000 square feet to fots larger than 10,000 square feet on an Incrementally proportional basis." This Is a misleading statement. The Initial Study should inform the public that the legality of this interpretation has been challenged and may not be legal. As documented in the IllEGAL PAST PRACTICE section, past application of the City's interpretation of R2 density is an ILLEGAL PAST PRACTICE. Page 1: /lEach alternative would permit .... attached .'duet" homes (two units attached, different owners)" This Is a statement with omissions. The Initial Study should specify "duet" as a new permitted use. 16