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Ms. Selena Kelaher Page 2 of 6 last meaningful modifications to the Economic Element to the General Plan took place in the late 1990s. By eliminating over three hundred thousand square feet of commercially designated space before completing the General Plan update, the City loses the ability to cogently and coherently plan for development. The amendment of a General Plan is a legislative decision. It would be entirely reasonable for the City to deny the application as opposed to engaging in piecemeal planning without a comprehensive and current understanding of both economic and development trends on a Citywide basis. Failure to Consider Economic Implications of the Loss of Office/Commercial Space The applicant and EIR assume that a 387,465 square foot office building may be built onsite pursuant to the existing zoning and General Plan designations. Although this size is debatable, it is shocking that the City would move forward on the basis of the applicant's financial projections without commissioning a study of the economic benefits associated with a comparable commercial buildout. Assembling the data supportive of such a study is not particularly difficult. In 2009, the City of Pasadena Chamber of Commerce prepared a study advocating for the preservation of office space. In addition to numerous one-time permit fees, the Chamber estimated that a 250,000 square foot building dramatically improve the local economy both in terms of direct tax revenue and secondary economic impacts. In contrast to residential development, the impacts to municipal services would be significantly lower for office. An excerpt of the study follows and the study itself is attached: [For a 250.000 square foot office building-4 Business license fees would bring $3,750 for the building itself and an additional $58,000 in business license fees for enterprises in the building. The 250,000 sf. building averages $687,500 in annual payments for electricity and $375,000 for other local utilities. That usage generates $134,000 in utility user taxes, again not including taxes paid on telephone and other communications services. That same 250,000 sf. office complex would generate approximately $50,000,000 annually in salaries and gross receipts of $125,000,000. The operations within the complex can be reasonably estimated to generate an additional $87,500,000 in salaries paid to supporting workers throughout the region and $231,250,000 in additional receipts in the region. The 1,000 workers in the building can be estimated to spend a small amount of their wages in local businesses, as well. Reasonably, $2,640,000 can be conservatively expected to flow into the local economy as a result of casual spending by office workers in a 250,000 sf. Complex. That is 50% of the already conservative average local expenditure of $110 per office employee, based on