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Attachments: CE JDEDZ Review 2017.pdf; Matt Sullivan DSIER Comn Analysis.pdf From: Matt Sullivan Sent: Wednesday, October 11, 2017 9:24 AM To: Kendall Granucci; Eric Luchini Cc: Nelson Fialho; Dan Sodergren Subject: 10/11/17 Planning Commission Comments Dear Planning Commission and Staff, SUPPLEMENTAL MATERIAL Provided to the Planning Commission After Distribution of Packet Date Distributed: IO1I I In 1 —� The following are my comments on the Johnson Drive EDZ proposal on your agenda tonight: 1. Economic Impact Analysis. The City's complete failure to include an economic impact/urban decay analysis in the, Draft SEIR rendered that document "basically and fundamentally inadequate" under CEQA. The City was therefore required to circulate its EIA - which appeared for the first time in Appendix A of the Final SEIR - for public review and comment per Sec. 15088.5 of the CEQA Guidelines. In addition, the EIA appears to be fundamentally flawed for the reasons laid out in the Civic Economics critique (which was submitted to the City Council in September and attached here for your convenience). In sum, the City's analysis of the JDEDZ economic and urban decay impacts is legally deficient under CEQA. 2. Air Quality/Health Risks from Toxic Air Contaminants. The Final SEIR's proposed mitigation measures 4.B-4, which requires a health risk assessment only if a new sensitive residential use is proposed within the EDZ area, is inadequate. The City should evaluate potential health risks to existing sensitive receptors in the Val Vista neighborhood now, both individually and cumulatively, from exposure to diesel particulates (DPM) not just from direct project operations, but from diesel vehicle traffic traveling to and from the project site. If there is an existing ambient cancer risk that exceeds applicable thresholds, then the project's cumulative health risk is likely to be significant and require mitigation. Without this analysis, the SEIR's analysis of health impacts is inadequate under CEQA. 3. Traffic. The Final SEIR's responses to my and others submitted comments on traffic impacts are inadequate and the SEIR fails to adequately disclose all potentially significant traffic impacts. I have attached my comments to the SEIR for your convenience, but I trust you have already read them in your review of the SEIR. 4. Funding for Infrastructure Improvements. The improper and potentially illegal diversion of TIF funds to pay for direct project mitigation conflicts with both General Plan polices and the rational of allowed use of the TIF as articulated in the 1998 TIF report. The project should pay for their direct transportation mitigations PLUS pay into the TIF for citywide circulation improvements. Costco is not being held to the same standard that all other developers in Pleasanton are. I have attached my analyses for these conclusions. 5. Project Approval Process. The so-called "streamlined" process for project approval is both undemocratic and inconsistent with past city practice. Large projects with significant impacts such as big box stores and hotels should be considered through a PUD process and subject to voter referendum, not staff level approvals without public notification or a hearing. The staff has implemented this strategy to undermine public opposition and the ability to overturn bad decisions by Council Council's as guaranteed to the public by the state constitution. 1 P14-0852 and PUD -105, JDEDZ - Public Comments Provided for October 11, 2017 Planning Commission Meeting 36