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455 Agency to date. In addition, it is clear that a. Negative Declaration is inappropriate as a d!sclosure document and ~s a violation of the California Commumty Redevelopment Law and the California Environmental Quality Act. Am : The number of new students that may be generated due to endment.is n. ot antic, ipated to deteriorate the existing environment at the Dtstnct's facfltties. The small number of new students that may be generated indirectly over the life of the Plan due to the Plan Amendment would not deteriorate the campus en.vironment by increasing traffic and noise. Any increased traffic, noise, etc. that may be generated by the students would be insignificant. The comment is correct in that increased enrollment requires the District to expand facilities. However, the ex~.ansion is required to meet a cumulative student increase, not specifically due to the proposed Plan Amendment. The District has not submitted ~nformation to the Agency that ifidicates or shows the proposed public works projects would increase the number of new students attending Dis!rict facilities. The Negative Declaration is the appropriate environmental document for evaluating the potential envaronmental effects associated with the proposed Plan Amendment and public works improvement projects. Comment: Using the Agency's projection of development of 2,415,000 square feet, the District has estimated an increased student enrollment of 801 students whic.h has a pr?sent value cost impact to the District of $17.9 million. Using the District's proje.ction of development square footage, based on all light industrial, the District has estimated an increasedstudent enrollment of 1,385 students which has a present value cost impact, to the District of $31 million. However, using what. the District feels is a more reasona.ble land use mix, the District projects 4.,659,344 squ. are feet of industrial, office and retail development, resulting in an estimated increase in student enrollment of 1,454 students and a present value cost of $32.6 million. The City Council should note that none of the Agency's l~roiections of de elopment come close to atta~.mng th.e proposed $2.6 billion hmit within the 40-year term as contamecl w~thin the proposed language of the Plan Amendment. This sugl~.ests that the Amended Plan may not be economically sound and feasible, or that if the Agency attains the limit, the impact on the District will be greater than either the Agency or the District has stated. Clearly, irrespective of the methodology used or the projection of development square footage, there will be. an impact on the District which has not been mitigated. The financial detriment stated by the District is the monetary expression of the environmental impact of the Amendment of the Plan. Because of the high enrollment condition of t e D~stnct s campus, es ~n comparison .to the capacity of t..hese facilities, together with the limited availability of capital financing 25