protect the greenbelt. they located and that it is all part of the city's established green belt. let me explain. it was conceived as a model after the garden city idea and it is identified as green space and park and considered as part of the san francisco design plan may, 1971. plan to strengthen city pattern to visually prominent landscaping. the design plan states under policies of city patterns in policy four where open spaces of any kind can be made more prominent by the addition of new or large scale landscaping such additions may be made to make the open spaces more visible in nearby neighborhoods. to respect existing landscaping

and avoid displacing or obscuring it. a strong effort should be made to replace it with new or equal purportion. the deir is evaluating of the landscape setting and the impact on the city wide green belt. housing continues. the project sponsor suggests "to protect the existing residence from displacement to a phasing plan designed to ensure all existing residents will be able to remain." and that this new apartment should be granted at the same rent control rate and subject to existing protections against rent nkedsings in the san francisco rent control ordinance.

in order to build the housing as described all garden apartments will be demolished. under the requirements of the general plan city ordinance discourage the demolition of said housing. page 15 states under direction of the general plan the department is predisposed the demolition application of said building. the project sponsor must prove with the preponderance of other plan policies to they want to demonstrate the building unsound and there is no

negative impact on historic resources in the project otherwise complies to the planning code in the design guidelines if applicable. not to let the owner's lack of proper maintenance ease the way for an approval to demolish to prepare the property. instructions for the demolition of housing identified as historic resources. california environmental quality act is used to evaluate the potential impact to a historical resource. guidelines put demolition on the list of actions that constitute a substantial change to the historic resource and i am quoting this in anticipation of the discussion that we will have. i am coming very quickly to an

end here. the existing development -- i'm sorry. with respect to what i just said, requires landmark and historic buildings be preserved. it fails to sufficiently examine why housing demolition is even necessary. the deir is deficient in fully addressing the specific policies and requirements that govern the demolition of housing. instead the developer will circumvent with a and use

designation that will exempt them from the requirements. the massive loss of san francisco rent controlled housing and promises to protecting the existing rent and guaranteeing rent controls in newly constructed housing. as repeatedly mentioned and compounded by state law, tenant law and observance of state law who have been in front of the commission expressed concern that there are serious questions about the enforcibility of promises to apply rent control. unless and until state law is clarified the city shouldn't even consider approving the large demolition of sound rent controlled housing the deir fails to identify and evaluate this risk. transportation. project sponsor suggests to

create a circulation and transportation system designed to reduce the amount of future automobile traffic. the deir summarizes the parking spaces which speaks to the contrary. the existing development contains 3,221 development units. in addition 1,59 cars on the street parking spaces were identified. the developers preferred proposal will have 8,900 dwelling units with 9,450 parks space accident -- spaces. this constitutes a net increase of 6,342 parking spaces as the net increase is not indicative of the planned stated goal for

reducing greenhouse emissions and reducing congestion generated by automobiles. the proposal is trending to resolve the congestion. in the absence of a request for lowering the ratios similar to the standards for recently approved projects the proposal is described does not elevate the discussion on suburb yeah which -- by propose to retain today's parking ratio for the next 20 to 30 years, the time frame for build out it will become a heavy traffic generated for decades to come. the deir fails to identify it

the impact. it is a single purpose developer that would lack hindsight, insight and foresight. i would like to briefly make a couple more comments on the infrastructure report. the project sponsor suggests to utilize the development practice in accordance with the plan such as street grid and open spaces to optimize full exposure. minimizing irrigation demands. none of the measures described

for exceptional or extraordinary. all of them can be achieved without demolition of the existing housing or massive deconstruction of the open landscaping. the san francisco sustain ability plan is a policy document that has not permitted the city to perform all actions addressed in this plan. the project sponsor plan is a plan with performance goals. the deir fails to examine the effectiveness of the proposed measures in the absence of a guarantee as this sustainibility plan will be frequently updated and reevaluated. this would need to be an important requirement if this plan is to remain relevant and in place for the next 20 to 30 years.

i have just discussed answers to question one and two. number two, are the project sponsors objective for the project desirable and realistic? no. most are self serving and many misleading. and with respect to the remaining four questions is it necessary to the community. no, not as proposed. it could be but would require major rework. considering the substance of the answers to questions one and two this project is not necessary. its value to the community is not evident and the significant and unavoidable impacts are not necessary for any reasons but to satisfy the agenda of the

project sponsor. have informed us of all aspects of the project. no. not if they have not properly described the project. have they described reasonable alternatives for the project? the only one is a significantly redesigned and phased project. number six have they employed all feasible means to substantially lessen the environmental effects of this proposal? no. most significant impacts are unavoidable. the total demolition of this historic property. the tradeoff between the proposed project and the significant unavoidable impact to historic resources, transportation, noise and air quality justified as acceptable? no they are not. this condition cludes my comment to the draft eir and i consider it inadequate.

>> thank you. i appreciate your comments. you made very compelling comments but most deal with the project itself and not e.i.r. the point of whether it will take over three decades does not necessarily mean a full 30 years. part of the construction can occur in the teens, 20s and 30s. it takes part in three decades. but it does not mean 30 years. it is hard to really focus a project this big to say it will be exactly 20 years. and i understand that. what it does say is that the public benefits will move in sequence with the project. again, not necessarily an e.i.r. issue but one we should be knowledgeable about. mr. crawford, could i ask you a question. we are talking about the existing towers.

my understanding of the situation is that you have to analyze the impact that you will have, what you are building but not necessarily analyzing the impact of what exists. is that correct? >> that is correct. the only extent to it is to analyze the impact of the towers is whether of an event of an earthquake there would be an effect such as the towers falling down and affecting life safety. >> in the newly built -- >> that's correct. >> presumably no worse than would be the case now. and possibly better. >> yeah. the main thing is that we examine what is the change. >> that is what i would bring up. the change is what we have to analyze. the impact of the change.

not the impact of preexisting. >> correct. >> thank you, sir. necessary and desirable. very good point that commissioner moore made but not an e.i.r. issue. this is a private development. we do not have to establish blight to go forward. i think it is well documented many of the existing townhouse units were built quickly and cheaply out of materials available at the time they were built. whether or not they would meet the criteria of the demolition standards we often discuss -- >> excuse me, please. >> the question of wloo not e.i.r. issues, oftentimes in fill housing fills up areas where we have one unit where the zoning is for three units

and we will add two units or add one. it can make the in fill housing consistent with the zoning and what is available in the existing land and what we feel would be available. and again, parking is being analyzed. you may not agree with the one to one parking but that is what will remain and that is what is desirable but it is not an e.i.r. issue. have they quickly analyzed what the effects of the parking will be. >> i would like to follow up with staff on one issue, the adequatey of the mitigation and there is a claim by the national trust and the other prferings -- preservation organization that the present set of mitigations for historic preservations are not adequate and the argument they are using

is that the mitigation has to be -- i can't remember the right word. but commensurate with the impact itself. the city of san francisco basically has instead of standard mitigations when historic resources are affected or demolished and include things like documenting the resource under historic american building survey standards on levels one, two, three or four, whatever they are. putting up a plaque. doing the exhibits, that type of thing. even salvaging parts of the demolished building if they are deemed to be significant features and such. but then you said there had to be a nexus. but there has been no nexus established in this case

between the actual demolition of 1500 units and however many buildings and these particular mitigation measures being proposed. that brings me to the other part of that which is that you said some of the suggestions such as monetary compensation have not been -- deviate from the standard ones the city usually uses. but unless we create the new ones we will always be stuck with the old ones. the city of oakland has fee based compensation. i don't know the exact formula that they use. i think it is based on a lynn year -- linear footage or something. long beach a while ago there were mitigations.

in any case there was a fund created on historic resources. this is slightly different but maybe it is related in the case of the imporium building there is a settlement between the developer and the city to create a fund. i can't see why we can't impose that type of mitigation without doing a nexus study. would you comment on that. >> we don't have to comment on it now. this can be something that we can perhaps get back in memo form at some point and deal with it on a broader basis and use it as a kicking off point

for discussing this particular issue. i would like to support commissioner moore. it was a well thought out and well analyzed statement from her standpoint. based on that and my own feelings i would like to make the motion to not certify the environmental impact report. >> second. >> before we go into the motion, i would like to submit my comments to the public record so they are part of what we do here. >> thank you.

>> commissioners, the motion on the floor is to not certify. on that motion. >> no. >> no. >> no. >> aye. >> aye. >> nay. >> aye. >> that motion fails on a 3-4 vote. >> move to certify. >> second. >> on the motion to certify the report. >> aye. >> aye. >> aye. >> no. >> no.

>> aye. >> no. >> that motion passes on a 4-3 vote. >> and at this time the court reporter needs a break. he has been typing away for the past few hours. we need to take that into consideration. so we are going to give him a 10-15-minute break sufficient? we will take a 15-minute break and be back at five after 6:00 and hear about delivering on the project after that.