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General Plan Update NOP EIR

From: Fisher George C. <"Fisher>
Date: Tue, 16 Jun 2015 14:16:03 -0700

June 16, 2015


Dear Honorable Mayor and City Council Members:


The Draft NOP EIR for General Plan Land Use Element and Circulation Element are for the entire city, and are not limited to M 2 area development and should be sent back for more accurate disclosure and revision. The NOP must accurately describe anticipated development throughout the city, and correct the erroneous maximum new non-residential development number of only 2.1 millions square feet in the M 2 area.


Staff acknowledges the maximum potential non-residential development in the M2 area is 3.85 million square feet (staff report p. 204) in addition to approved or built development. Not only should the approved but un-built amount be added to the maximum 3.85 million square feet to allow comprehension of the total new development being considered, but the full 3.85 million number be used. The NOP misleadingly states only 2.1 million square feet non-residential need be included alleging that the existing General Plan includes development of the approximately 1.75 million square feet difference between the acknowledged 3.85 million square feet of new development. The current General Plan cannot provide accurate numbers because it was limited to 2010 build-out numbers, which was actually exceeded before 2000. Post 2010 development was not studied, and needs to be presently included in any General Plan revision.


In addition, no analysis has been done of the number of new jobs, new housing needed, or direct city financial benefits or burdens caused by the new non-residential development. That analysis needs to be done and accurately and completely described before any Council approval of a Draft EIR for General Plan revision. Failure to do so will lead to ambiguity, misunderstandings, and lack of clarity for developers or residents. Council has promised clear communication.


Sincerely, George C. Fisher
Received on Tue Jun 16 2015 - 14:12:48 PDT

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