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<br />City_arid County of San Francisco: Office of City Attorney <br />Louise H. Renne, <br />City A1tqrney <br />Mr. Wayne Rasmussen June 13, 1996 <br />Principal Planner <br />200 Old Bernal Avenue <br />P.O. Box 520 <br />Pleasanton, CA 94566-0802 <br />(Hand delivered at City Council meeting on June 13, 1996.) <br />Re: Comments on Draft Responses to Comments on the Draft Em. <br />For Pleasanton General Plan Amendment <br />Dear Mr. Rasmussen: <br />I have reviewed the responses to comments that the San Francisco Water Depanment <br />(SFWD) submitted on the Draft EIR for the General Plan in a letter dated March 21, 1996. I <br />. request that you carefully consider the following points before the City Council approves the Fmal <br />EIR. because the responses do not meet the standards imposed under the California Environmental <br />Quality Act. <br />The answer to the first comment in SFWD's letter is not responsive. You have not 1, 2 <br />explained why the DEIR fails to discuss consistency between the County's General Plan and the <br />proposed Plea.santon Plan, notwithstanding that nearly fifty square miles of territory covered by <br />Pleasanton's Plan is in the County's jurisdiction. The point of the comment is that the proposal to 3 <br />reduce the current annual limit on building permits for housing construction by more than fifty <br />percent is, under state law, "presumed to have an impact on the supply of residential units <br />available in an area which includes territory outside the jurisdiction of the city." (Evid. Code Sec. <br />669.5.) Your response, that" limits already exist and are not newly-proposed under the draft. <br />General Plan" ignores the fact that there is a new proposal to impose additiona1limitations"and <br />the environmental implications of that policy change on regional housing needs should be <br />disclosed in the DEnt. ..' <br />The response also states that under the proposed General Plan amendment the reduction 4 <br />in the number of housing units that could be approved b ,emore theoretical than practical." That <br />is not an accurate statement; the limit as proposed is absolute, and the regional housing supply <br />could be correspo~dingly reduced in any given year as a direct result of that prohibition. In <br />addition, other general. plan amendments when read together will have the real effect of reducing <br />and deferring housing construction in Pleasanton. Given the significant regional transportation 5 <br />and air quality impacts associated with urban sprawl in the region. the EIR. might, for example, <br />have analyzed where the housing demand that would not be accommodated in Pleasanton would <br />be diverted to instead. Your response fails to explain why such analysis is not necessary. <br />The recent amendment to the County General Plan for the area carefuUy considered 6 <br />(416) 554-3SOC Fox Plaza, 13$0 M3J1cet Street, SIXth Floor San Francisco 94102.5408 <br />