if we go forward with this plan, we will see that continuing if we do not add sufficient housing. this body has the capacity to add more housing. do not listen to the fake arguments by the blue condo owners who are worried about cancer and not advocating for public transit. that is -- i am not going to use the word, but please. . >> thank you for your comments. >> madam, clerk. to laura clark's point we are speaking for certain appeals than others. you have two opportunities to speak you have to split your time, if possible. i know this is awkward. i don't think we have had an appeal with so many appellants. they don't all agree together. i want that clear for the members of the public.

this is just for the appeal. next speaker. >> i am peter mission economic you agency in support of the appeal. a few points which have been mentioned which i want to highlight and raise questions for concern for our agency. over our concern is that we are not feeling convinced and we are hearing from the soma community there isn't a clear equity first lens hasn't been wapellotured. this is a long term structural plan. these can move sideways over time we know as environment moves quickly as we found in eastern neighborhoods. we would like to see more socio economic study which captured that we were mitigating the impacteds to make sure the most

vulnerable residents are protected under the plan going forward. there is pdr pressure to those communities critical to maintaining good paying jobs typically for immigrants moving to the community as opposed to the higher end office jobs, yes, we want folks in the jobs but that is a different scenario, office space one you have the most critical concerns. also, looking at what numbers we are using. if it is 5.5 million square feet at 151 square feet last year's number i get 36,000 jobs. i think the 2018 number is even lower, i think we can expect more jobs by the time this is built. lastly then, i think looking at the impact around the city, we know one out of every five wealthy residents move to the mission.

other neighborhoods have similar impacts. i think that issue of state density bonus if that is contradict we would like to see that state density bonus recalculated into these if it hasn't been. that is a critical question. >> thank you. next speaker, please. >> you i am james fahey. i am here to speak at a later you subject. this is coming up. i am listening to what is going on and reading about the project. if there is a fundamental process issue to be addressed by the city. i think it would help city to help consider design thinking as opposed to traditional design. the difference is the traditional design makes the

decision up front and tries to kind of power through barriers to get approval to get finalized. design thinking actually as you can see in the diagram begins with a lot of empathy in the beginning and listening to input from individuals upfront and it is also something that is put forth by stanford university you can find information on youtube about this. it is common here. a lot of comments here at this point in time shouldn't becoming in at this point in the process. it should be much further early on. thank you very much. >> thank you for your comments. next speaker, please. >> good afternoon, supervisor. i am a research analyst at the hotel workers' union. i will leave it to the clerk if i all speaking in the right section of speakers. i will do my best.

as you curthe rare -- consider the various appeals today we want to speak about how they affect a particular project whose developers we are in negotiation. local two reaches agreements that when hotel projects will be built we want the workers to have a fair process to join the union that is a substantial community benefit for good jobs. we work with our sisters and brothers in construction to make sure union construction of the hotels will be built with the union construction. we reached agreements on two projects and are in agreement with the third. what we want to ask is as the appeals are considered there is a question of the height limits to affect the project. we would ask as the appeals are considered we ask the height

limits the one vasar. needs to be prevents. there is a lot but we want to flag and we also really would hope that in addition to the question of the height limits fofor the particular project you honor the tremendous work to fight the gentrification on the soma community and you work very hard to make sure the plan incorporates the safe guards that these people have come here today to ask for. thank you. >> thank you for your comments. next speaker, please. >> you new directions.

the giants were here a couple months ago. their project is 9,000 jobs, 1500 homes, 909 market rates. 120% down. are we going to be creating homes for 90% that san francisco can't afford new direction? are we going to be homing the cupertino workers. people you ask for votes are here. are you including them in the neighborhood? the caregivers, the union was here saying save our jobs. the hospital wants to save more money. mine is an end extraction. they the stuff from the ground and make money from doing that.

building real estate in san francisco is an extraction. they are going to make a lot of money. we are going to live with it. for an llc that has an address somewhere else, part of our healthy community, no, not your owners, no, not your neighbors. a new direction. you are asked to do this. a healthy neighborhood. healthy community is what we should be doing in every planning that we create here. this is a healthy community that you won't be able to open your windows. not exactly what we are counting on. it is kind of like a big republican sellout. refugees from capitalism are on our streets. 90% of the people in the community can't afford to live

there. thank you. >> thank you for your comments. you next speaker. >> good evening. i am a worker of the south market district. i support the appeal of central soma and request to support their appeal because of the housing. it [ inaudible ] the studies the impact of residential development as though it will be used for residences. the environmental impacts of short term rentals and commercial uses are different from residential uses. it does not address the las

vegas of affordability. it does not address the lack of affordability of housing incentives by the plan and socio economic makeup of the residents that will result. >> thank you. next speaker, please. >> i am here to vote in favor of the central sole mama -- soma p. >> we will call that in a moment. any other members on the certification of the appeal? now is your opportunity.

are there any last minute speaker os this item? seeing none we are going -- yes. >> to be clear we are speak on the matter of the appeals before you? great, thank you for your patience. good evening, board. i am representing key development site you. i am speaking in opposition of the appeal. >> madam president. this is on behalf of the apple laboratories. -- appellants. >> there is a clarification. >> madam clerk, this is very confusing. state in the beginning you are speaking in support of which appellant. you can stay but come back again and speak against a different appellant. make that clear. you can't speak against an appellant in public comment.

make it clear which appellant you are in behalf of. then you can come back and be specific. >> i will come back. thank you. >> now that we have closed public comment. i want to give 10 minutes to the representatives of the planning department to make their presentation. please set the clock for the planning department. thank you. are you ready? >> good evening, my name is liz white, planning department staff. joining me are the environmental review offer, the environmental planner and the principal planners, senior transportation

planner. the item before you is the appeal of the central soma environmental impact report. it is a comprehensive plan for the southern portion of the central subway transit line. the evaluation of the central plan is problematic. the assessment of environmental impacts based on components required and would facilitate the goals. they certified the e.i.r. and approved the project may 10, 2018. four appeals to the board of supervisorses were filed. richard on behalf of the neighbors and sf blew and on behalf of the market community action network, phillip on behalf of llc and john on behalf of the neighborhood consortium.

they received four appeal letters and responded to comments on the accuracy of the air in the responses. in total the department provided theory responses to the appeal letters. as described on the july 9, august 30, september 10, the central plan is adequate, complete and complies with the california environmental quality act. the guidelines chapter 31 of the administrative code. in this presentation i will highlight the five, 2.5 issues brought forth today and departments responses. this presentation will not address all issues from appeal letters. number one they allege the plan will exacerbates the san francisco job housing ratio and result in gentrification and displacement.

the analysis found the jobs housing ratio is lower given the plan's focus on production and distribution and repair building space increased opportunity for housing and increasing housing of ford built. no evidence it would result in displacements above lovel levels out the plan no evidence it would result in significant physical environmental effects as a result of get friction from -- genty fiction. it will have a significant vmt impact. the threshold with respect is to demonstrate that per capita is reduced to 10% below the 2005 20052005 levels, 87% below the

average. for employees that is 69% below the 2005 regional average. no evidence to suggest emt impacts would be significant. the thresholds is a per capital metric, not absolute total amount. regarding traffic the san francisco planning commission replaced level of service or automobile delay to determine the significance of transportation impacts. the planning commission developmented 19579 on march 3rd 2016 for all projects moving forward. the transportation impact analysis is based on bmt. you issue number three. the appellants allegations it does not adequately mitigate air quality impacts and fails to mitigate the measure us. based on the draft e.i.r. they

identified one feasible air quality mitigation measure maq five e for 13 air quality measure in the e.i.r. this measure require the city to explore the feasibility of additional measure us such as portable air filtration devices. other measure are lure -- are already includes. issue four. the appellant contend the e.i.r. did not adequately evaluate seismic safety. the i believe study found the -- the initial study does not require analysis of existing environmental conditions unless it would exacerbate thaw condition. it evaluated the plan and found

the plan would not expose people or structures to substantial adverse effect related to ground shaking. all projects will be designed with the most current san francisco building code would not exacerbate any existing seismic conditions. five, the appellant contends they have increased house you go alternatives. they reduce the impacts. appellantses request without specifying the parameters. by increasing building height such an alternative could increase the significant wind impact in the e.i.r. and shadow im packets to a significant level. within the height limit could result in additional vehicle trips increase the air quality and noise impacts in the e.i.r.

because these alliteratives would inhe -- alternatives they do not require analysis of these alternatives. i respectfully note many of the comments addressed the merits of the plan no information is raised that changes our conclusion it is adequate. they have not provided substantial evidence to support claims it is inadequate. the department recommends the board uphold the central plan e.i.r. and deny the appeal. that concludes the department presentation. we are available for any questions. thank you. >> thank you, president cohen. i have a number of questions for

the planning department. i first want to bring up the issue of the air quality and cancer risk studied under the plan. i think we heard several interpretations from appellant on the cancer risk. i want to better understands what it is the e.i.r. studied and also concluded. we had one appellant state the central soma plan was equivalents to 10 oil refineries and different numbers 20 times what the risk should be, 226 per 1 million chances of getting cancer. could we clarify that because i think that is very confusing. none of us want a plan that increases cancer risk by that magnitude in the south market or in san francisco. >> yes, i am jessica range. i will respond to your question.

the e.i.r. analyzed two scenarios. one is existing plus plan. that assumes all of the development would occur as soon as the plan is adopted using 2014 emission factors. that is where the cancer risk of 226 comes from. that is at one individual receptor point. we are in accordance with the methods we use from the air district we identify the maximum alley exposed receptor points. it is maximum not what occurs throughout the plan. second was a 20/40 scenario assuming the plan is built out in year 2040 using 2040 emissions factors. that is where the maximum impact is 8.1 as mentioned by some of

the other appellants. >> i think that it is important to state that in planer english. i don't think that is reassuring for the resident in the south market neighborhood. if all of the development was to happen this year in the next five years, that we would be increasing cancer risk exposure to 226 over a million? is that what the e.i.r. concluded? >> if it was all to occur in 2014, let's say, that is what 226 cancer risk is from. using 2014 emissions factors. if it is built on the year 2014, which is not a realistic scenario, as you know. we did publish it in 2013 and did not anticipate that we would be here five years later, you

know, discussions the e.i.r. at this point. >> i know this is a difficult question. what is the realistic timeline for the complete build out of central soma and all of the projects entitled and improved? >> i am going to let my colleagues in city wide address that. >> i ask this question because i imagine that the response i would get from constituents what if we built faster? we have had a good economy and built this much since the 1906 earthquake. it is feasible we could build very quickly. i am disregarding a number of factors down the horizon. i think it is important to reassure residents that we are not greatly increasing cancer risk exposure through the approval of this plan.

>> supervisors the planning staff. the potential build out of the plan as jessica mentioned they are long-range plans. the horizon of 25 years is what we assume is the assumed build out of the plan, of the approximately 16 million square feet it is hard to see that built out. you have to remember to the extent that a significant amount is commercial development that will meter it out. some of these large projects take many years to build at the minimum between entitles would be approved and construction the first buildings not being completed for three or four years at the earliest. >> there is a push among the office developers to reform to

allow more of the office development to be built quicker. it seems that this would argue against the board of supervisors revising the process so we have a slow metering process to ensure we don't build out too quickly. would you like to respond to that? >> i believe that is a policy matter for the board to take up. i am not the air quality expert. most of the impacts are auto and vehicular emissions not construction of the buildings or operations of the buildings specifically. it is not clear that building the buildings faster would result in more impact sooner. >> the other point i would like to make is each of the individual projects still have to undergo their own environmental review, and all of those projects require individual studies and

preparation of community plan evaluation. following approval of the e.i.r. and plan there is environmental review that needs done for the projects. >> for the members of the public so they understand, could you explain what that would entail? what additional environmental review the large development projects would be under taken by the planning department if we certify the e.i.r. plan before us today. >> any of the office projects mentioned would have to undergo a project level analysis. they would have to have their own individual noise analyzes, traffic nailing cease, air quality analyzes to make sure they don't result in new significant impacts not already disclosed in the e.i.r., provided there are new significant impacts. those would require their own e.i.r. and that would be much

longer process. the hsd housing projects would not require separate environmental review. >> what part of the plan is settings aside money for air quality mitigation including improvements on the freeway around greening and mitigation of impacts from the freeway and distribution you have the filter to existing buildings that aren't meeting the current standards. to the extent that buildings are built sooner that would be available sooner and as you saw most of the plan area suffers from not excellent air quality. to the extent the money is available sooner residents could

benefit sooner from the rams. >> would you talk about the recommendations the planning defendant is make you go around the freeway beyond funding for air filters for individual units. >> the specific programs would be determining the future working not just with the community but the public health department and utilities commission and experts to identify what greening, landscaping and trees which abothewhichwould be best suitede you the environment in the area. >> funding through the cfd. >> yes largely through the cfd. >> which we would have a citizens advisory commission to help guide the revenue. >> the funds mechanisms from the

plan would be routed through the cfds or formed as a result of this plan. >> since we are on the environment tell greening, one you have the requests was green walls on buildings taller than 160 feet within the project. could you speak to that? >> i guess the feasibility or what the challenges would be? that is a request that is reasonable and i would like to consider pursuing within the plan process. i am curious what the feasibility or challenges of this would be. >> the plan augments and increasing the green roof requirement in the plan area on top of the existing city wide

green roof requirements. that is a major sustainabilities and air quality improvement of the plan. we haven't evaluated green walls. we are happy to study the feasibility of the large buildings in the plan area. certainly we would encourage and hope to facilitate greens of all façades of buildings. >> i would like to pursue this in the next month. the difficulty with requiring green roofs with taller buildings is because you have the rooftop furniture they are required. we only required for 160 feet and below. it doesn't x out the possibility of more green walls. as we build up the south market we will improve the air quality for families and residents around not decreasing air quality. i would like to work with the

planning department over the next month on that issue. the blue h way brought up the map. i was hoping we could get clarification on what the map means. the way it looks for the average lay person, is that the pink areas are in a new danger zone around air quality. if you could talk a little bit about the current state and what the central soma plan would do to increase risk in the neighborhood or not. >> supervisor, jescould range. -- jessica range. it is based on health code article 38 in preparation for passing the requirements that buildings within that zone needs to comply with enhanced

ventilation requirements. we used that map in our analysis to determine whether or not a project would result in a significant health risk impact. the standards for that are whether or not a project would -- within the zone is whether or not cancer risk from all model sources exceed 100 per one million or pm2.5 levels exceed 10. in certain areas south of market the standard is lowered to 90 per millio and nine. those numbers are based on very conservative -- based on e.p.a. for the cancer risk of 100 per million based on e.p.a. recommendation. we lower to 90 per million for certain areas. the cancer risk of 10 -- sorry

the concentration of 10 is actually based on the federal clean air act which has a standard for 12. it is even much lower than the federal standard. i don't know if that is helpful comparison. >> i think i understood you. i am not sure that everyone else did. what you are states is that the recommendation level is 100 per million? in the south of market we decided to take a more restrictive position which is 90 per million. what we are estimates is 8.1 per million if the buildout takes 20.1 years. >> that is the plan's contribution. >> it has come up that we haven't adequately studied the impact of tnc which is new in

san francisco. many of our e.i.r.s did not have the opportunity to study the impact of the uber and lyft and so for that reason the e.i.r. is inadequate and studies of vehicle miles traveled within the area because we were not able to study thatshire. what is your response to that? >> we did in the e.i.r. recognize that tncs may increase bmt. there is not enough data right now to be able to analyze the impacts of plan or specific project increase in tnc use and increase in bmt. the e.i.r. made a good faith effort to disclose that tncs could increase the bmt but in terms of the threshold that is

whether or not it reduce us the levels to 10% below 2005 regional averages and as liz mentioned in her presentation the impact would be well below those thresholds. >> many members of the public have spoken about the jobs housing and balance within the central soma plan. it is important to reiterate to look at it from city wide perspective not within the central soma plan. this is downtown area and we are going to have a jobs imbalance. it is correct four the members of the public to say there will be pressure to build more house you go to make up. we should be building more housing, affordable house you go to mitigate the impacts of increased jobs within this plan.

what is the response to planning in terms of studying a higher housing density alternative? could that be done through alternative e.i.r. i am not questioning this e.i.r. if this board want to study an alternative over the next couple months to examine an alternative to build more house you go could we do a supplemental e.i.r. to study that? >> yes we could. we would analyze the proposal before us and do a supplemental e.i.r. if no new significant impacts we would not need a new such mental. >> how long would that take? >> iit depends on the findings. we would have to do studies. an addendum -- i don't know if you would like to.

about three to six months for addendum when the studies are completed and e.i.r. would take longer we would have to prepare a supplemental e.i.r. and have public comment. that would take longer. about a year. >> some of the comments made today also state you had this plan did not take into account enough of what our residents would like to see in the growth of our city verse the needs of developers. some of the, you know industries in need for more office versus need for more affordable housing. in did district i represent we have quite a number of youth and families, far more than i think people realize. a point was made that i thought was a good one is being that it

is a significant amount of the space in this plan, what can we do to increase youth and family amenities in the popo design standards? >> you are correct that the plan does offer a lot of policies to require popos at the larger sites. it does offer some incentives. the way the popos policies is one conveyor foot to every -- one square feet for every 50 feet of development. that is playgrounds and dog runs and dog parts. what we would like to see in

open spaces serving youth and families as well as broader soma community. >> i have a lot of different issues. i am jumping back and forth between the issues. a number of -- i think there is a lot of comments from the public and the supervisors ensuring as we grow the population of workers and residents we take into account for ensuring space four schools, child care and planning centers. what has been done and what possibilities do we have to increase those amenities and resources? >> joshua with planning staff. as to schools we have been coordinating closely over the last 18 months to look at the

issue of school capacity and the needs for schools for a growing city. through the course of planning this working on this plan, the school district enrollment is growing and turned around from low enrollments 10 years ago. together we have been looking closely to help them with data analysis and evaluating where they might have capacity issue in the future, also helping advance planning for new schools already on the books, specifically, there is land set aside in mission bay for a new school set aside in the mission bay plan. the school district has $50 million from the recent bond to move construction you have the school. we are helping them to the extent they need on planning for did you facility and evaluating the population for the future. we have worked with supervisor

fewer to help the school district and city to work on this bring in other agencies including capital planning, oawd and others to work with the school district to plan for the future. as it speaks to other community facilities beyond schools, this plan we work closely with the parks department to look at parks and recreation needs across the south market. this plan will be providing substantial funds for reconstruction expansion of the rec center outside of the plan boundary but serve the soma community. i would provides funds including new facility impact fee. this will be the first neighborhood to have that to provide health centers and things of that nature.

>> i am going back to what i think is -- by the way i apologize. i am on the edge of the plan and the environmental study. it is difficult because appellantses brought up a number of plan concerns as environmental concerns. there should be a opportunity for the city to respond to the appellant responses. i am coming back to the psychmiss issue that -- seismic issue that came up with you was was the appeal. i think san francisco has to build and the district i represent has taken the brunt of that construction over the last eight years. we are doing 80% of the commercial and residential development because our district has allowed for it. our constituents supported that along with the district

supervisors. i also know that we are building on soil that is perhaps not as solid as other parts of the city, and i wanted to hear a response on the considerations that were done. i am not convinced it is not a sequa concern. i want to hear more from the city attorney or from planning about the consideration why it was not studied in the e.i.r. and what we can do to mitigate the real concerns around building so much, which i support, but in the heart of the city where i think we have a lot more water and less bedrock. >> planning staff again.

the e.i.r. did evaluation seismic considerations in the initial study. it is an autops an appendix cird for a 30-day public review period. the initial study found the plan itself would not exacerbate size nick risk. that is what we are required to look at is whether the plan would exacerbates the seismic risk. there is no doubts the plan would encourage development within the area. there is established case law about sequa does not apply to bringing people to the hazardous area if the project does not somehowicsomehow exacerbate that condition.

vicky wonk is here and lisa is here to discuss more about the funds that are available as part of the plan for preservation to up great some existing buildings. >> before we do that, sues per visor peskin has his name. i have an opportunity for him to you ask questions as well. >> let me start out with. i was on the board of supervisors when we approved the e.i.r. for millennium tower. we are having a bad day in san francisco and they just discovered a huge crack in a steel beam in the transbay terminal. i was on this board when we approved the e.i.r. for bayview hunters point shipyard and have lived long enough to see radium

dials on parcel a. i have my eyes wider open than ever. in so far as we all acknowledge that is substrates and soils in the south you have market are not good, i was quite interested in the consortium's arguments and responses to the letter from planning dated august 29th. one thing that ms. wong can state the appendix checklist does require identification of whether a product would expose people or structure to substantial adverse effects including risk of loss, juror death involves you rupture of earthquake fault, size nick related ground -- seismic you gd

failure. you come to the conclusion that is less than significant because we are relying on the california building cold and san francisco building codes and administrative bulletins 82 and 83 which i can say don't give me necessarily a lot of confidence. i do understand the argument that you are making as to extent buildings not having to be part of the analysis. i think that is very clear, but saying that is less than significant because we are going to rely on our dent of knowledge inspection and -- department of building code section investigations i don't know if that is thorough adequate and complete if you want to respond

to that. i am not familiar with whatever case you are citing. >> i think if i remember the case that you are citing, that was that traffic impacts are not covered, but i will leave it to the attorneys. >> victoria wong. the case she referring to is california industry association versus bay area air quality

management 2015 supreme court case. that case addressed the question of whether an agency is subject to sequa. if they are required to analyze the impact. the court held that agencies are not generally required to analyze the impact of existing environmental conditions on a project's future. if the proposed project risks exacerbating those pre-existing environmental hazards or conditions they must analyze the impact of the hazards on the future residents or users. the principal is that it requires analysis of the project impact on the environment as

opposed to the environment impact on the project. >> let me try a hypothetical for you if you there are professional that write and talk about this. if the weight of construction could exacerbate earthquake fault activity, would that not then require further analysis under sequa? >> if there were information that the project would exacerbate an existing hazard, yes that should be address you had. that wouldn't be with regard to exist u existing buildings but new construction. >> no argument there. >> that is it for now.

>> we feel confident the new construction our new development won't increase our danger or hazards to residents and workers seismically? >> that is what the e.i.r. finds the plan itself would not. another hypothetical a consequent development project comes in under the soma plan that require us a specific analysis with a technical report to analyze the very specific circumstances and if that project were to be found to result in increased hazard that would trigger further environmental review through e.i.r. or mitigated negative declaration. >> can you explain that so we

understand the e.i.r. four the area plan versus youved projects to -- individual projects to follow. there is confusion if we approve the e.i.r. today it is wholesale approval of everything in the plan. people won't be able to oppose on provide comments to individual projects that they are concerned with with in the central soma plan. >> yes, the e.i.r. in the beginning of the draft it talks about intended uses of e.i.r. aside from projects qualify you had as housing sustain ability district receiving approval all other projects reliant on the central soma plan are required to undergo their own project specific analysis, they would be compared against the findings in the e.i.r. if that would result in new

significant impacts, any site specific impacts associated with that project then those projects are required to do their own mitigated negative declaration our e.i.r. >> there is a perception this e.i.r. is approving all of the individual projects within the plan. what are we approving today if we certify this e.i.r.? >> generally if you approve the e.i.r. and the plan you are approving the zoning map. >> we are not approving. the environmental study. what aspect of the plan are we in essence certifying the environmental study for if we certify the e.i.r. today? >> is that question clear?

>> if each project was in the plan requires its own environmental analysis what is the e.i.r. we are approving today? >> the zoning. you are approving the change in zoning. allowable uses as well as the height. that is the short version of that. >> consumif this board decides e more house nugth housing and exd the house you go in the current plan what would happen? >> so each specific project would be evaluated and determined to -- through that evaluation we look at whether or not it would result in any new significant impact.

whether or not the amount of housing versus jobs that we projected would occur in the e.i.r. happens as we projected or if the balance shifts to more housing versus less jobs, what we are analyzing the environmental effects of those. there is no cap on the amount of housing units or job growth, but what we are analyzing is the environmental effect from that. >> if we certify it is complete and adequate but we decide as a need for the city we need to build more house you go in this plan, not because you have environmental impact but because of the policy goal of the city we want to build more house you go. this e.i.r. studied a max number of house you go within the central soma plan. if over time project by project the board started approving

significantly more house you go than studied under this what would occur? >> each project would under go environmental analysis. it would be compared to impact of the plan. if it is within the plan level e.i.r., no further analysis is done. if we have reason to believe there would be new significant cumulative impacts due to the nature of the build out those projects would require additional environmental review. >> there is flexibility four the board to significantly increase house you go in this plan? i am seeing disagreement. i want to clarify the questions. i realize i am asking questions

about the plan versus the e.i.r. before us today which the board is determines whether it wants to certify or return to the planning department. because so up of the comment which was so appropriate and thoughtful is about the plan itself, i think it is important what the board of supervisors is doing with the e.i.r. i am interested in increasing housing within the central sole maplan. it made you sense years ago in view you have the time it takes it feels outdated today. that doesn't speak to the e.i.r. before us but to the plan itself. if the board in the wisdom and planning commission decide you had to add housing to the central soma plan, would we be able to beyond the number studied in the e.i.r. project by

project? >> we would have to analyze those changes to the plan and we would have to determine whether they fit within the e.i.r. and we would do an addendum. if they don't fit within the impact we would have to do supplemental e.i.r. >> after we hear public comment on that i have a number of asks for the planning department for that not related to the completeness of the e.i.r. but the plan itself. from is a lot of work to do to make sure the plan is right four the residents here in san francisco. my last set of questions and i see our colleagues with questions as well. the housing sustainabilities district is up for a reason why the e.i.r. is not complete.

it came later down the road not studied as part of environmental impact. would you respond. >> we give response to this in the original appeal response. to summarize. 8073 was adopted and effective january of this year to allow to city to establish the housing sustainabilities district. it was appropriate to add this to the e.i.r. and during the response because the sustainabilities district does not change the physical parameters of the plan, height, bulk, density. it does not change the if i i callen -- physical environmental effects and is appropriate to add to the e.i.r. >> we have questions from other

colleagues. >> supervisor fewer. >> i have a clarification. i think you said the measure that you are using to the job to housing ratio is lower than existing level than the existing level now. your measure is really this point in time are jobs to housing ratio and whether it is above the current level or below the current level i is that correct? >> we study the impact against the baseline existing conditions at the time, and that is why we come paired the plan's -- compared the plan with the existing conditions. >> if we were to say the exis c