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463 <br /> <br />does not render the Agency's offer unreasonable. The <br />Agency's offer included a calculation of the "cost-of-detriment" <br />incurred to date (since 1982) which is not relevant when <br />calculating "present value". <br /> <br />Lastly, the Agency staff has rejected the Dist.rict's calculation <br />of detriment purportedly caused by t.he housing set-aside funds. <br />The District's calculation of this detrtment is based on <br />erroneous subsidy assumptions (discussed above) and <br />convoluted interp.retatio.ns of the City's General Plan which are <br />further discussed in Section 4 of this response. <br /> <br />"District's Election to Tax Increment Pursuant to Section 33676 of the <br />Health and Safe .ty Code" <br /> <br />This section documents the District's adoption of a reso. lution <br />pursuant to Section 33676(a)(1) and (2). No objection is raised and, <br />therefore, no response is required; however, it should be noted that <br />the Agency staff believes, under current law, that the adoption of this <br />resolution has no effect on the proposed Amendment to the Plan. <br /> <br />SANTA ANA UNIFIED SCHOOL DISTRICT <br /> <br />Objection: The Committee (Fiscal Review) recommended that an EIR be <br />prepared by the Agency for the South Harbor Boulevard Amendment.. In its <br />response, the Agency staff does not appear to understand that the taxing <br />entities believe an EIR should be prepared to address.environmental <br />consequences of the.amendment and the implementanon of new. projects. A <br />substantial increase in potential Agency activities will be authorized as the <br />tax increment cap is increased from $1.09 million to $2.6 billion. Such a <br />change in scope lustifies a detailed enwronment, al analysis. Also, the sixty <br />percent (60%) low and moderate income set-aside was lmp.osed on the Plan <br />after approval of the original EIR. This change alone const.ltutes a sufficient <br />basis for EIR preparation. However, the Agency characterized the taxing <br />entities' concerns improperly as relating only to financial bu_rden or <br />detriment. Even if the amendment does not propose modifications to <br />existing land uses or projects, an EIR would still be necessapj. This <br />additional environmental analysis should also entail consideration of <br />financial burden and detriment on the taxing entities. <br /> <br />Resnonse: At this time, the public works projects listed in the Plan <br />Amendment are the only projects th.e A. gency proposes to c. onst .tact. <br />However, additional development within the Project Area is anticipated to <br />occur over the life of the Plan: There are no development plans proposed for <br />any of the vacant parcels within the Project Area or any other parcels within <br />the Project Area. Any detailed environmental analysis of future <br />development on the vacant parcels, or any other pa. rcels in the P. roject Area, <br />wou. ld be speculative at thi.s time since specificproject information is not <br />available. Subsequent emaronmentai analysis for future development of <br />parcels in compliance with CEQA will be conducted at the time formal <br />planning approval applications .are submitted to the City. Once planning <br />approval applications are su.brmtted, specific project information will be <br />known so that ad. equate environmental evaluations can be conducted for a <br />project. Should it be determined at that time a project could have significant <br /> <br /> <br />