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Attached are excerpts from the BAAQMD CEQA Guidelines addressing toxic air contaminant risks, an issue <br /> that I and.others have brought up repeatedly, a discussion of this issue and the EIR from a colleague and air <br /> quality expert whom I consulted, and asection from a recent EIR completed in Fresno that contains the kind of <br /> analysis I have been requesting..., <br /> My comments to the Planning Commission, for your information, were as follows: <br /> 1. Economic Impact Analysis. The City's complete failure to include an economic impact/urban decay <br /> analysis in the Draft SEIR rendered that document "basically and fundamentally inadequate" under CEQA. The <br /> City was therefore required to circulate its EIA - which appeared for the first time in Appendix A of the Final <br /> SEIR- for public review and comment per Sec. 15088.5 of the CEQA Guidelines. In addition,the EIA appears <br /> to be fundamentally flawed for the reasons laid out in the Civic Economics critique (which was submitted to the <br /> City Council in September and attached here for your convenience). In sum,the City's analysis of the JDEDZ <br /> economic and urban decay impacts is legally deficient under CEQA. <br /> 2. Air Quality/Health Risks from Toxic Air Contaminants. The Final SEIR's proposedmitigation <br /> measures 4.B-4,which requires a health risk assessment only if a new sensitive residential use is proposed <br /> within the EDZ area, is inadequate. The City should evaluate potential health risks to existing sensitive <br /> receptors in the Val Vista neighborhood now,both individually and cumulatively, from exposure to diesel <br /> particulates (DPM)not just from direct project operations,but from diesel vehicle traffic traveling to and from <br /> the project site. If there is an existing ambient cancer risk that exceeds applicable thresholds, then the project's <br /> cumulative health risk is likely to be significant and require mitigation. Without this analysis, the SEIR's <br /> analysis of health impacts is inadequate under CEQA. <br /> 3. Traffic. The Final SEIR's responses to my and others submitted comments on traffic impacts are <br /> inadequate and the SEIR fails to adequately disclose all potentially significant traffic impacts. I have attached <br /> my comments to the SEIR for your convenience, but I trust you have already read them in your review of the <br /> SEIR. <br /> 4. Funding for Infrastructure Improvements. The improper and potentially illegal diversion of TIF funds to <br /> pay for direct project mitigation conflicts with both General Plan polices and the rational of allowed use of the <br /> TIF as articulated in the 1998 TIF report. The project should pay for their direct transportation mitigations <br /> PLUS pay into the TIF for citywide circulation improvements. Costco is not being held to the same standard <br /> that all other developers in Pleasanton are. I have attached my analyses for these conclusions. <br /> 5. Project Approval Process. The so-called"streamlined"process for project approval is both <br /> undemocratic and inconsistent with past city practice. Large projects with significant impacts such as big box <br /> stores and hotels should be considered through a PUD process and subject to voter referendum,not staff level <br /> approvals without public notification or a hearing. The staff has implemented this strategy to undermine public <br /> opposition and the ability to overturn bad decisions by Council Council's as guaranteed to the public by the <br /> state constitution. <br /> Please confirm receipt of this email and attachments. <br /> Thank you. <br /> Matt Sullivan <br /> Pleasanton Citizens for Responsible Growth-- <br /> Matt Sullivan <br /> 2 <br />