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7A Page 93 As documented in the NOT CONSISTENT WITH PAST DEVELOPMENT section, one has to go back more than thirty (30) years to find a project that exceeds the current single-family density of 8.7 family units per acre. In addition, If this statement is referencing the City's current Interpretation of R2 density, 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 3: UStaff has determined that the most permissive (highest density) of the three alternatives analyzed, the alternative providing for one addItional housing unit for each 2',500 square feet of site area above 10,000 'square feet, most accurately reflects the City's past practices with respect to applying the existing R-2 zoning district requirements to lots greater than 10,000 square feet." This is a false statement as detailed in the NOT CONSISTENT WITH PAST DEVELOPMENT section. Based on the information provided for the Kentfield Project in 2009, one would have to ignore al/ development from the past 30 years to have any chance of making this statement true. Basically, ignore all development buift under the current R2 density standards. In 1977 the current density standards were established. Page 3: "As a result, the highest densty alternative presented to the Planning Commission and Oty Council would, in essence, codify the City's existing practice with respect to its implementation of the R- 2 zoning district for lots greater than 10,000 square feet." 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 IUEGAl PAST pRACTICE. p'age 3: "... Staff has concluded that the three alternatives ... would result in new development that is either less than or equal to the level of development that the City would experience under its existlng R- 2 ordinance, but would not Increase the level of development anticipated by the CIty under its existing ordlnance.1I This Is a false statement. As detailed in the ILLEGAL PAST PRACf1ce section; the highest density alternative increases the maximum single-famUy density from 8.7 family units per acre to 17.4 family units per acre. Page 8: "The project involves an amendment to an existing residential ordinance that may slightly Increase the number of housing unit in several residential areas dispersed throughout the CitV." 19