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MainPlace Transformation Project <br />City Council Agenda Item 75D <br />June 4, 2019 <br />Page 16 <br />including GHG emissions, energy use, traffic, public services, among others. Here, neither the <br />Addendum nor the Specific Plan itself disclose even an estimate of how many people will live <br />the in 1,900 proposed units. Indeed the Addendum does not disclose how many bedrooms each <br />unit will be. The number of bedrooms per unit will have a direct impact on the number of people <br />inhabiting the 1,900 new units, and the environmental impacts of those units. Without even an <br />estimate of the proposed residential population, the Project's description is incomplete <br />Moreover, CEQA requires an analysis of the full build out of a project, meaning the <br />maximum size project that could be built under the entitlements sought. Stanislaus Natural <br />Heritage Project b. County of Stanislaus (1996) 48 Ca1.App.4th 182, 195-206. Without a limit on how <br />many bedrooms each unit will be, the CEQA analysis must assume the units will all be built with the <br />maximum number of bedrooms permitted. This was not what was analyzed in the Addendum. <br />CONCLUSION <br />For the above and other reasons, the Planning Commission should decline to recommend <br />the City Council approve the Addendum, and instead direct Planning Staff to prepare and <br />circulate an FIR for public review. The City may not rely on the nearly 40-year old 1983 EIR. <br />Sincerely, <br />Rebecca Davis <br />