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<br />Mayor Ben Tarver and <br />Members of the city council <br />May 28, 1996 <br />Page 2 <br /> We acknowledge that the subject of several of the <br />letters was the adequacy of the draft General Plan and that the <br />Draft EIR was not specifically mentioned. However, other letters <br />received and responded to, address comments to the project itself 3 <br />as well as the EIR. In fact, it appears as though the author of <br />the Response to comments document has arbitrarily decided to <br />"pick and choose" between the comments, responding to some and <br />ignoring others. This practice flies in the face of the good <br />faith requirement expressed in the CEQA Guidelines. Further, the <br />HCD letter addresses issues regarding the project's Housing <br />Element which were not raised in the DEIR and for which no <br />information exists in the record which would provide the council <br />an ability to make a "reasoned choice" among project alternatives <br />or to evaluate and potentiallY mitigate project impacts related <br />to the Housing Element. <br /> In addition, the Response to comments document does not <br />provide adequate responses to housinq element related comments in <br />other letters. SpecificallY, response L17 to the Miller, starr <br />and Regalia letter is conclusory. CEQA requires that responses <br />to comments provide a factual basis. "A conclusory statement 4 <br />unsupported by empirical or experimental data, scientific <br />authorities, or explanatory information of any kind not only <br />fails to crystalize issues but affords no basis for comparison of <br />the problESS involved in the alternatives." (Clearv v. county of <br />stanislaus (1981) 118 Cal.APp.3d 348 at 358) The response <br />implies that 3,232 housing units (the surplus of 8,100 housing <br />units over those 4,868 needed to accommodate Pleasanton workers) <br />would be sufficient to accommodate those households who desire to <br />live in Pleasanton but work elsewhere. There is no factual basis <br />given to justify this conclusion and its seems especiallY <br />perfunctory given the fact that currently over two thirds of the <br />housing units ;n pleasanton are occupied by persons who do not <br />work in Pleasanton1. <br /> . <br />1 21t of 31,863 jobs equals approximatelY 6,6l9 job holders <br />who both live and work in pleasanton. 21,180 existing housing <br />units mi.Das 6,.619 persons who both live and work in Pleasanton <br />(assuming conservatively that no household has more than one <br />Pleasan~ worker); leaves 14,489 housing units occupied by <br />households with no member who works in pleasanton. More than two <br />thirdS of the total households. <br />VIN1!\34I17 <br />101311.1 <br />