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DSEIR Comments 11/21/15 Submitted by Matt Sullivan Air Quality Element, Program 2.1: Implement programs from the Land Use Element to provide mixed-use developments, locate high-density uses near transit facilities, and provide neighborhood -serving retail uses convenient to residential neighborhoods. These programs would reduce vehicle trips and vehicle miles traveled, thus reducing air - pollutant emissions. The DSEIR Impact 4.B-3 indicates that the operation of new uses within the proposed EDZ area would conflict, even after mitigation, with or obstruct implementation of the Bay Area 2010 Clean Air Plan, and this impact would be significant and unavoidable. Given the traffic, air quality, and land use impacts of this project identified in the DSEIR, the EDZ clearly does not meet the standards of Sustainable Development as articulated in the General Plan. Please explain why the DSEIR did not find that the project does not comply with these very important policies to promote Sustainable Development in the City of Pleasanton. 6. Numerous studies have demonstrated the negative economic impacts that big box stores have on local economies and local communities, especially when tax or other incentives are provided to developers and big box store operators. One study that demonstrates this can be found here: https://ilsr.org/dark-store-tax-tactic-makes-big-box-stores-terrible-deal-for-cities/ . These impacts can cause existing, locally owned retail outlets to go out of business due to loss of sales resulting in damage and "urban decay" to the community from closing stores and vacant or underutilized properties. Business in downtown Pleasanton are especially vulnerable to this effect. The Fiscal Impact Analysis included in the DSEIR is inadequate. This analysis relies of "rule of thumb" and general factors from like uses to determine revenue that would be provided from the project to the city. A full, comprehensive economicand fiscal analysis, prepared by an independent qualified firm, should be prepared for this project and include, at a minimum, evaluation of the following criteria: o A complete market forecast of the proposed uses of the EDZ based on project -specific criteria without reliance on "rule of thumb" and general factors o Full pro -forma analysis of the Big Box, hotel, and other retail/office uses comparing revenue, costs, and profit realized from the project. This should include a pro -forma analysis of developer costs and profit o A full evaluation of project infrastructure costs, including freeway improvements and how those costs affect the profitability of the proposed project uses if funded by the developer or individual uses. o A fiscal evaluation of revenue benefits for the city based on the above analysis o A full evaluation of ay incentives provided by the city for this project including funding of infrastructure improvements or sales and property tax reductions and discounts. This would include an analysis of how these incentives effect city gained revenue from this project over a 30 -year span 2 P14-0852 and PUD -105, JDEDZ - Public Comments Provided for October 11, 2017 Planning Commission Meeting 58