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Comment Letter 62 PUBLIC COMMENTS: Johnson Drive Economic Development Zone Luchini p. 2 After carefully reviewing the various city memorandums and documents, the subject SEIR and the Pleasanton Municipal Code (in particular section 18.120 — Nonconforming Uses), AT&T requests to be placed on record, with respect to public commentary pertaining to the JDEDZ and Draft SEIR, as follows: 1. The SEIR fails to consider the complexity and operational value of the WC, as related to the multitude of services being provided from the site, all of which are geographically and spatially located to maximize service efficiencies. The WC is fully utilized, the parking area fronting Johnson Drive is required to accommodate employee parking (approximately 120 employees) and fleet vehicles (at this time, 156 vehicles are assigned to the site). Any disruption to operations at the site would be extremely costly to AT&T. 2. It is our interpretation that the proposed rezoning of the WC from PUD-G&LI to PUD -C, pursuant to the proposed list of permitted and conditional uses (a WC is not listed), and the General Plan amendment of the WC from Business Park to Retail, Highway and Service Commercial, Business and Professional Offices, will effectively render the WC a use which is not permitted, thereby forcing it to become a legal non -conforming use, subject to section 18.120 of the Pleasanton Municipal Code. The SEIR fails to discuss the resultant creation of legal non -conformities within the JDEDZ, the economic disparity that, over time would be created by the presence of properties that are not permitted to expand and grow (with only repair and maintenance allowed) and most importantly, the incremental premium that would be required to relocate, buyout or move a specific and unique use, such as a WC. A Work Center is extremely costly to move or relocate, alternative sites are scarce and movement creates efficiency losses, forcing the operator to incur the cost burdens of an alternative site, thereby increasing the cost of service to the customer. The analysis and site selection process alone, associated with movement of a WC is of material consideration. Before the subject site could recycle under the intentions of the JDEDZ, these cost premiums would be incurred, lowering the economic benefit of the JDEDZ accordingly. The economic modeling done under the SEIR did not account for the foregoing considerations and thus the economic benefits derived are inaccurate. 3. By effectively making the WC a legal non -conforming use, the JDEDZ essentially eliminates the opportunity for AT&T and abutting owners to look at land planning and development alternatives wherein major parcels could be reconfigured through lot line adjustments or similar subdivision actions, enabling certain existing uses to remain and be strategically incorporated into a superior land development configuration. The SEIR fails to identify this scenario as a viable development alternative or option. 4. No longer the "telephone company" of the past, the AT&T WC is essentially at the center of a dynamic, fluid and flexible modern network. For example, in the event of a disaster, network traffic and personnel may shift to this facility, enabling AT&T to maximize its response efficiency, through customized resource allocation. The DEIR does not evaluate or consider this 62-2 62-3 62-4 62-5 September — December 2015 4-173 P14-0852 and PUD -105, JDEDZ - Public Comments Provided for October 11, 2017 Planning Commission Meeting 4