Public Comment

Welcome to another chapter in Berkeley’s GOWN SWALLOWS TOWN saga. My comments below address the Proposed Project’s deficiencies with two-dozen narrative “nuggets.” Most of my questions are tossed into a “caboose” at the end.

Though the Upper Hearst Development is exceedingly complicated, I think it can be reduced to a relatively simple formula:

DVP > P3 > ASM > $

where: DVP = dean’s vanity project

P3 = public private* partnership

ASM = aerial strip mine

* with outsource partners ACC and CHF

My recommendations to the authors of the CEQA draft document are also uncomplicated:

First, SCRAP the Minor LRDP Amendment concerning density in the Campus Environs Housing Zone. The changes advocated in Appendix B (DSEIR, p 251) rest on the flimsiest of assertions concerning “an exception” needed in support of university “excellence.”

Second, SEVER the updated population baseline discussion from the DSEIR. The relationship of existing campus headcount with 2020 LRDP projections is sufficiently important to merit its own independent CEQA document. The City of Berkeley agrees. 

Third, if there’s still sufficient resolve among project backers to move forward, REDRAFT and RECIRCULATE that part of the DSEIR that relates to the Upper Hearst Development. There’s much that can be improved both within the DSEIR itself and the public process surrounding it. 

1. Trouble at the railroad yard 

We first suspected something was amiss last December when Cal’s Finals Week came and went without an announcement. Where was the Goldman project’s draft EIR? Normally these things are as predictable as curbside dog waste. For years, we’ve watched how environmental pufferbellies routinely exit UC Berkeley’s CEQA railroad just before holidays. Review and response time can be kept to a minimum this way. “What’s going on?” we wondered. Then came January. Then Groundhog Day. Still nothing. 

2. Scoping flashback 

Back in March 2018 everything seemed to be on a fast track. One year to the day after UCB’s Office of the Vice Chancellor Real Estate and the Goldman School of Public Policy jointly issued a Request for Qualifications (RFQ), GSPP Dean Henry Brady hosted the obligatory CEQA scoping session in the bowels of Beta Theta Pi. Pens and comment cards were offered to the handful of neighbors who bothered to appear. What began as a schmooze-fest with project partisans amid poster boards soon morphed into a military-style debriefing with slideshow. The dean and his team members spoke. We stood and listened. No time for questions, except via the cards. No refreshments were offered, except tea in the adjacent room. 

3. Nacht, Nacht, who’s there? 

For us, it was déjà vu all over again, except less comfortable and more downscale. A mere nineteen years earlier, in the same venerable building, we enjoyed the hospitality of Dean Michael Nacht. We listened to dean and team extol the virtues of a proposed annex. It was to occupy the small parking lot immediately west of Beta Theta Pi. A generous grant (north of $20m) from the Goldman Foundation would secure the project (and school’s name change). Refreshments were plentiful and delicious. 

4. Vanity project in perspective  

It’s instructive to juxtapose the two construction initiatives by the two Goldman School deans. The first, the Goldman Annex building, essentially doubled the school’s usable space—from 7,500 sq ft to around 15k sq ft. Lost in the process were 22 parking spaces and several mature live oaks on Le Roy Avenue. Dean Brady’s expansion plan, by contrast, will triple GSPP’s current size (which now includes 4,500 sq ft of rented space at Memorial Stadium) to around 60k! Moreover, the current incarnation of the school’s expansion plans permanently removes around 200 spaces from the adjacent Upper Hearst Parking Structure and lot (UPHS & UPHL). The Campus Landscape Architect has already condemned the two large coast redwoods on La Loma Avenue as non-specimen trees. 

5. DSEIR hairball coughed up, finally 

One can hardly say it was worth the wait. The Draft Supplemental Environmental Impact Report (DSEIR) surfaced on Feburary 20^th, eleven and 23 months after the scoping session and RFQ, respectively. The document embeds the dean’s dream into a nightmare matrix of disappeared parking for UPHS/L patrons and housing pie-in-the-sky for UCB’s development partners. Further clouding its nearly 800 pages is a tenuous (Frankenstein-esque?) linkage to UCB’s 2020 Long Range Development Plan (LRDP). 

6. Rube Goldberg would be proud 

Why complicate unnecessarily an already thoroughly tangled environmental document? One likely possibility: it’s part of the defendant’s legal strategy in Save Berkeley’s Neighborhoods v. The Regents of the University of California, Alameda County Superior Court Case No. RG18902751. In his Scoping Comments response last September (DSEIR, pp 220-222) to the mid-August Notice of Preparation (NOP), attorney Tom Lippe argues that key “structural” problems are created by combining two distinct CEQA projects in the same EIR. 

7. Want your scrambled eggs yoked or un-yoked? 

Chief among the plaintiff’s issues is UCB’s burgeoning student enrollment and unmitigated impacts. Current headcounts have grown increasingly out-of-synch with baselines in the 14-year-old LRDP. Enrollment increases are a “CEQA project” in their own right, Lippe maintains, and “should not be yoked to the EIR for a major capital project that may face unknown and potentially protracted delays.” University lawyers no doubt hope that certification of the Goldman SEIR by UC Regents will moot the pesky Save Berkeley’s Neighborhoods case. 

8. An exceptional edifice of excellence 

Another complication is that the revenue-generating end of the project site was previously designated by UCB for merely medium-density development. Not a problem. Fix it with a “minor amendment” to the 2020 LRDP and goose it up to “high density.” The reader is reassured in Appendix B (DSEIR, p 251) that this adjustment is a ”rare exception” in support of the university’s continuing quest for excellence. LRDP boilerplate for the new Cal Aquatics Center on Bancroft Avenue is cited as precedent. All this can be found in section 3.1.14 City Environs Framework of the 2020 LRDP. Subhead: “Plan every new project to respect and enhance the character, livability, and cultural vitality of our city environs.” 

9. Geotechnical backfill 

The more-density-in-support-of-excellence argument is buttressed by a substantial geotechnical section (Appendix D) comprising over 43 percent of the 776-page DSEIR. Is this because the proposed residential complex would sit precariously on the western edge of the Alquist-Priolo Special Study Zone? The appendix is adorned with colorful geologic maps and cross-sections of borings (drilled in mid-September 2017). Among the fascinating details revealed is that UCB’s geologist in 1970 observed that “a well-developed fault trace intersects the northeast corner of parking structure.” Not really a problem, conclude the authors, in their “desk study.” “Oh, to be a UC ‘non-fault” contractor!” exclaimed a geologist neighbor of ours. 

10. Digging to China 

Execution of the ambitious Goldman project will necessitate ambitious excavation. How much? Here is what the DSEIR (p 41) says about grading: 

Grading would involve an estimated 13,147 cubic yards of cut and 140 cubic yards of fill, resulting in a net export of 13,007 cubic yards of material for offsite disposal. In addition, demolition of the existing parking areas would require the export of approximately 7,000 cubic yards of material from the Project site. The maximum depth of excavation would be approximately 23 feet below grade level. 

11. Mighty Stanley as a metric 

Place yourself next to La Loma Avenue at the southeast corner of Goldman’s one-acre-sized opportunity site. Cross Hearst Avenue and proceed south along Gayley Road for just 0.2km (a distance that corresponds to the approximate distance between the Hayward Fault (DSEIR, p 251) and the Goldman site. Now look to your right. There you’ll find the massive Stanley Biosciences and Bioengineering Facility. Eleven stories tall (with three below grade) this structure replaced the Old Stanley Hall, which was demolished in 2005. Within its 285k-sq-ft interior, Stanley contains a three auditoriums (with a total of 465 seats) and a multimedia classroom (with 45 more). It was completed in 2007 on a budget of $162.3m. 

12. Tiny Goldman plays catch-up  

GSPP’s new 40k-sq-ft academic building will consist of office, classroom, and event space. We are told that the latter, with a seating capacity of 300, will accommodate up to 450 visitors at maximum capacity. So, Goldman with 450 (not all seated) vs Stanley with a just few more. GSPP’s ambitious adjacent housing complex, including residential units and parking, would be approximately 220 gsf. So, with the subterranean parking tossed in on the Goldman side, we see a GSPP/Stanley size ratio of 220+40 / 285 = 0.91. Should we imagine Stanley Hall lying on its side? 

13. Drive-by transportation analysis 

The DSEIR informs us (p 161) that Fehr & Peers, UCB’s go-to traffic consultant, collected peak-period vehicle counts at four LHPS/L parking driveways on May Day last year. They figured that, with the loss of 207 existing parking spaces, trip-generation numbers will drop once the new housing complex opens its doors. Whoopee! But it’s too early to celebrate. A look back at the July 2000 DEIR for the Goldman Annex project shows at least a couple paragraphs devoted to parking in the vicinity. Why parking is addressed in a small Goldman project but not a huge one is baffling. Was F&P’s myopia related to their own failings or that of whomever wrote their contract and paid their fees? 

14. Unnoticed neighbors 

More on the myopia theme: the two CEQA public hearings revealed more than we ever wanted to know about the Physical & Environmental Planning (PEP) team’s interest in exposing UCB’s project plans to the public. We live only a block north of the proposed project site, yet we received no hardcopy notice for either public hearing. As far as we know, none of our neighbors received any notice either—except for a couple on Ridge Road. In the good old days, we would find postcards from PEP in our mailbox. 

15. Hearings in Kamchatka 

Adding to the insult were the hearing venues. The first hearing—intended originally to be the only one—was tucked into the Alumni House across campus on a Berkeley City Council evening. Objections from Councilmembers shamed PEP into serving up a second helping nine days later. The venue for that hearing, Room 150, University Hall on Addison Street, was no closer to the project site than the first, although it was closer to City Hall. 

16. Retail window vs wholesale back door 

For us, the real eye-opener (or stick-in-the-eye?) came several days after public hearing #1. We were tipped off by a Daily Cal piece devoted to a UC Regents meeting at UCLA on Wednesday, March 13^th, ONE DAY AFTER THE FIRST PUBLIC HEARING. Lo and behold, we learn that GSPP Dean Brady and UCB Vice Chancellor Rosemarie Rae regaled the Finance and Capital Strategies Committee (F&CSC) with the wonders of the Upper Hearst Development project. The whole scheme and its considerable benefits are summarized in a nine-page package (Discussion Item F7) from UC’s Office of the President (UCOP). If only the poor schmucks who schlepped to the Alumni House the previous evening had known about CEQA’s back door. 

17. P3 to the rescue 

Word-for-word, UCOP’s tidy F&CSC discussion item yields far more useful information than the voluminous DSEIR. For instance, its Executive Summary declares: “This project is delivered through a public-private partnership and funded through a third-party debt financing structure, supplemented with equity from GSPP’s fundraising efforts.” Hmmm. Why don’t we see that juicy tidbit anywhere in the DSEIR? Reading on, we discover that Goldman was outbid in 2014 on a 12,800-sq-ft property three blocks away on Euclid Avenue. An attempt to lease 20k sq ft of space from the nearby Church Divinity School similarly collapsed. 

18. Texas-style outsourcing 

A March 2017 RFQ eventually brought American Campus Communities into Goldman’s orbit. Austin TX-based ACC is a publicly-traded real-estate investment trust that has become a big player in the burgeoning “P3” industry. It develops and owns both on- and off-campus dormitories for universities eager to outsource the risk and financial responsibility for new dorm construction and management. Wikipedia cites ACC as the largest private dormitory manager in the country by the end of 2016. The new 700+-bed Blackwell Hall, on Dana between Bancroft and Durant, is an ACC project. 

19. Alabama-style financing 

The F7 revelations continue in an “Ownership and Financing Structure” paragraph: 

The land and parking garage will be ground leased from the University to Collegiate Housing Foundation (CHF), a qualified nonprofit 501(c)(3) organization, and the project is proposed to be financed through the issuance of tax-exempt bonds. The development team, led by ACC, will develop and manage the construction of all components of the project on behalf of CHF. . . Rental revenues from the new apartments would support the debt service of the parking structure, and maintenance, operations, and debt service of the housing construction. CHF will own the project until the project debt is repaid. The apartments will be operated and managed by ACC . . . 

CHF is based in Fairhope AL. 

20. UCOP has fallen for P3s 

Back in July 2010, UCOP’s Budget and Capital Resources operation released “Private Public Partnerships at the University of California.” Revised in June 2013, the document claims that UC had successfully employed or was in the process of planning 81 Public Private Partnerships throughout the state. Under “Critical Factors” it suggested that for UC, the use of a PPP is most effective for projects that: 

• Are situated off-campus on land not owned by UC; and/or
• Generate stable income; and/or
• Represent a building type commonly developed privately, such as rental housing, commercial office buildings, hotels, and generic lab facilities.

Within UCOP’s P3 publication are three case studies which illustrate the use of PPPs at UC. One of them is a 545-unit, 1564-bed student housing project at UC Irvine that utilized a ground lease on 24 acres. It began service in 2006. Total project cost worked out to just over $58k per bed. The project was developed by an arm of ACC under a contract with CHF, the project manager. It was financed with a 30-year, tax-exempt bond issue. IS THIS A LIKELY MODEL FOR THE UPPER HEARST DEVELOPMENT? UCOP’s F7 item says that upon repayment of the project debt, the ground lease with the owner will terminate and project ownership will transfer back to UCB. (If we all should live so long.) Note that CHF’s original underwriter for the project was the now-defunct Lehman Brothers. 

22. Built-in escape hatch 

Embedded in the 2017 RFQ, and repeated numerous times in subsequent documents and public hearings, is the notion that the Proposed Project will develop housing appropriate for new faculty, visiting scholars, graduate students and postdoctoral scholars. Subtext: upscale tenants = upscale rents. “If feasible, the project will offer rents below market rates for these populations either directly or through rent scholarships.” But what if scholarships are unavailable or ACC has difficulty filling their new digs with the right people? Not to worry. “The units may be offered to the University population if there is not adequate interest from these groups after good faith marketing efforts,” F&CSC members were informed. 

23. Find your place to love 

A glance at ACC’s home page < https://www.americancampus.com/ > rewards the visitor with ear-to-ear collegiate smiles and snappy slogans: 

“Find your place to love.” 

_{"Where students love living. ® "} 

_{IT'S NOT JUST OUR COMPANY TAGLINE. IT'S HOW WE RUN OUR BUSINESS EVERY SINGLE DAY.} 

_{We believe every student should love where they live. That's why our number one}  

_{priority is delivering the best possible experience for students -- at every}  

_{price point. It's the goal we continually strive for, and the mantra that shapes}  

_{our values as an operation.} 

24. Landlord from hell? 

Despite their considerable self-esteem, ACC as a dorm manager earns but one out of five possible Yelp stars from their residents: 

_{https://www.yelp.com/biz/american-campus-communities-austin} 

_{1 of 19 reviews} 

_{9/29/2018 

DO NOT live at any american campus community. I have currently}  

_{been dealing with my roof leaking for a month now. They have not done anything}  

_{despite my repeated calls, emails, and talks with maintenance people who are}  

_{currently doing OTHER jobs. This is ridiculous, I do not ever recommend living}  

_{at one of these communities, or ever having to deal with any of their employees.}  

_{The incompetence is astounding.} 

_{https://www.yelp.com/not_recommended_reviews/american-campus-communities-austin} 

_{1 of 12 reviews} 

_{2/5/2019 

If I could give this company 0 stars I wouldn't hesitate. This is}  

_{the most monopolistic, horrendous, inhumane and quick money scheming company}  

_{that I've ever encountered. Comcast doesn't compare, Verizon doesn't compare,}  

_{nothing compares. I wish I could tell you I was being dramatic, but alas, this}  

_{is the worst organization that has ever existed.} 

QUESTIONS CABOOSE 

GSPP 

What is the present enrollment at GSPP? 

What was the enrollment at GSPP in 2000? 

How much additional enrollment capacity was made possible by the GSPP Annex? 

What is the present staff count at GSPP? 

What was the staff count at GSPP in 2000? 

How much additional staff capacity was made possible by the GSPP Annex? 

What is the present faculty count at GSPP? 

What was the faculty count at GSPP in 2000? 

How much additional faculty capacity was made possible by the GSPP Annex? 

Roughly, how many of GSPP’s present faculty and staff regularly park at UHPS/L? 

How does GSPP fit into the 1990 LRDP’s “precinct” guidelines? Back then, GSPP’s location was smack in the “Engineering and Earth Sciences” precinct. “The purpose of organization by precinct is to recognize the existing clusters of uses, and to strengthen them through the assignment of existing space and the allocation of new development sites.” (p 4-39). Could you please explain? By this logic, shouldn’t GSPP be located closer to Berkeley Law and the Haas School of Business? 

Public hearings 

Who selected the time and place for the first DSEIR public hearing? Was that decision the responsibility of UC Berkeley’s Physical & Environmental Planning (PEP) team? Were they not aware that it was a City of Berkeley Council night? 

Originally, only one public hearing was contemplated (on March 12^th) for the DSEIR, correct? Why was the Alumni House selected as the hearing venue and not some room considerably closer to the project site and the affected neighbors? Did UCB originally TRY to get a closer hearing venue? If not, why not? 

We know of only one pair of neighbors who received hardcopy notice of the first DSEIR public hearing. They happen to live on Ridge Road, directly across the street from the north end of the proposed project. Was there anyone else who received hardcopy notice of the hearing? Do you have a list of noticed residents you could provide? If not, why not? 

If this DSEIR is recirculated, is there any chance that future public hearing(s) will be held at a location more convenient to the impacted neighbors? 

A second DSEIR hearing was scheduled for March 21^st. We’ve heard that it was in response to complaints from the City of Berkeley. Is that true? If so, in the FSEIR (or revised DSEIR) could you please include any correspondence or documentation that COB wanted a second hearing? 

Was UCB’s noticing procedure for the second DSEIR hearing any more vigorous than for the first one? 

UHPS/L 

Barring unforeseen seismic events, how many more years of useful life do university engineers expect the Upper Hearst Parking Structure (UHPS) to provide? How often is UHPS inspected for structural problems? Approximately, what do those inspections cost? 

In her comments before the UC Regents F&CSC on March 13^th, UCB Vice Chancellor of Finance Rosemarie Rae reportedly said that the Upper Hearst Parking Structure has a series of infrastructural flaws. Is this true? If so, could you please document them? Why is there no such information in the DSEIR? 

In his remarks at the second public hearing, GSPP Dean Henry Brady reported that “we made the decision early on that it was worth paying $30,000 for each space that was eliminated.” Could you please elaborate on the derivation of this number? Does it apply to UCB Parking & Transportation spaces in general or only at specific places on campus? Is there a P&T price difference between covered and uncovered spaces? Can you offer any supporting documents to back up Dean Brady’s calculations? 

Has there been any internal documentation (within P&T or elsewhere) that analyzes the number of F (faculty/staff) and C (central campus) permit users of the UHPS and UHPL facilities? If so, could you please include it in the FSEIR (or recirculated DSEIR)? 

Professor Eli Yablonovitch suggested at the March 21^st public hearing that the loss of parking required to facilitate Dean Brady’s capital improvements risks triggering the loss of faculty and staff within one of UCB’s greatest assets, the College of Engineering. Why wasn’t this concern anticipated and addressed in the DSEIR? 

In addition, Professor Yablonovich expressed doubts about GSPP’s current ability to finance their ambitious project. The first step, he said, “is going to tear down a parking structure that would cost $20m to replace, which doesn’t make any sense.” Is this cost estimate realistic? 

The recent emergence of an online petition by the Ad Hoc Committee for Review of the GSPP Project to “stop demolition of the Upper Hearst Parking Garage” illuminates some of the unfortunate tradeoffs associated with the proposed project. Some of the 500+ petitioners 

have included “Reasons for signing” with their ID information. The reasons range from silly to serious, but would it be possible to include comments from the petitioners in the FSEIR or recirculated DSEIR? 

Project design 

Without the Minor Amendment to the LRDP, how many dwelling units would be appropriate for this parcel? Is it 40 per acre? 

What, for example, is the comparable allowable density at Cloyne Court? Or on the La Loma side of the Foothill Residence Hall? 

Construction  

We are told that the maximum grading depth at the Upper Hearst Development site will be 23 feet. Is there any likelihood that the project contemplated will have to dig deeper than that? 

The DSEIR claims that the site will require 20,000 cubic feet of grading and debris removal. For comparison, approximately how much material was removed for the Goldman Annex site? 

What about de-watering machinery? Will it be required permanently on the Proposed Project site? If so, what might be the likely annual operating costs? 

Is it correct that Stanley Hall has permanently installed de-watering machinery in its subterranean levels? If so, can you say (roughly) what this costs to operate annually? 

Do Stanley Hall’s subterranean levels offer any useful guidance for the below-grade parking contemplated for the GSPP project site? Could you please elaborate? 

What sized trucks (in terms of carrying capacity) are likely to be used in removing the grading materials and concrete pieces? Five cubic feet? Ten cubic feet? Something else? 

With the expectation of 20,000 cubic feet of these materials to be removed from the project site, how many individual truck trips does that represent? 

During construction, how much of the construction traffic is likely to be directed along the Ridge Road corridor, especially between Euclid and La Loma?. Will the FSEIR (or a revised DSEIR) devote any attention to this? If not, why not? 

During construction, is there any possibility that trucks and machinery can be required to start no earlier than 8am and stop no later than 5pm? If not, what about 7:30am? Will work on weekends be allowed? 

Is there any construction scenario in which the two redwoods adjacent to the UHPS can be saved? If not, why not? 

What about the other street trees adjacent to the project site on La Loma Avenue and Ridge Road? 

How much of the streets adjacent (especially Ridge Road and La Loma) to the project site will be rendered unusable during the course of construction? For how long? 

Similarly, what about the sidewalks adjacent to the project site? 

Do you anticipate that a crane will be required to construct the Upper Hearst Project? 

Roughly, how many workers do you anticipate will be required at different construction stages of the Proposed Project? How many of them are likely to travel to the site in their own vehicle(s). Where are they likely to park? 

Traffic/parking 

Will the FSEIR (or a revised DSEIR) devote attention to the very tight on-street parking conditions in the area and how they might be impacted by the GSPP project, both during the months of construction and thereafter? If not, why not? Can the excess parking demand from special events like Greek Theatre concerts, commencement, and Memorial Stadium football games be included in the analysis? 

Would it be possible to expand the analysis to include traffic flow estimates before, during, and after the project on nearby residential streets like La Loma, Ridge, Le Roy, Le Conte, and Euclid? 

Shadow study 

Will the FSEIR (or a revised DSEIR) include a shadow study of the proposed residential complex? If not, why not? 

Renderings 

Will the FSEIR (or a revised DSEIR) include more renderings of the proposed project in relation to existing nearby structures—ie, on the Hearst, La Loma, and Ridge Road sides? 

If not, why not? For example, it’s very hard to judge how the residential complex will look relative to the existing Foothill dorms on La Loma. 

P3 partners 

The 2017 RFQ says that the Berkeley campus will seek authority from the UC Regents to enter into a ground lease/development agreement with the selected developer. We know now that ACC is the selected developer. Has a ground lease been signed? If so, could you please include a copy in the FSEIR or a recirculated DSEIR? If not, at what stage in the process might a ground lease be signed? 

Is Blackwell Hall ACC’s first housing project on or near the UCB campus? If not, what other projects on or near the UCB campus has ACC participated in or bid on? Do the student residents at Blackwell pay rent directly to ACC or is there some intermediary? 

Does CHF currently participate in any projects on or near the UCB campus? If so, could you please list them? 

UCOP suggests in a 2010/13 document that to succeed, projects delivered under a PPP require a well-thought-through “Basis of Design” document (BOD) that delineates design specifications and operating parameters. Does any BOD currently exist for the Goldman P3 project? If so, could you please include it in the FSEIR or revised DSEIR? If not, is a BOD planned at this time? 

LRDP 

The Minor LRDP Amendment looks like a key enabler for this project. Other than for the Aquatics Center on Bancroft, has there been any other time since the 2020 LRDP was created that UCB/UCOP has asked for a Minor Amendment? If so, could you please list the case(s)? 

Other 

UCOP listed the Upper Hearst Garage as one of nine “Potential Housing Sites” in Table 3 on page 4 of discussion item F1, “UPDATE ON STUDENT HOUSING, BERKELEY CAMPUS” at the 15 March 2017 meeting of the F&CSC. Yet in late June 2018, a UCB RFQ titled “Stage 1 Request for Qualifications: UC Berkeley Housing Initiative” was released in late June 2018. Its Section III B, “Potential Project Sites” lists eight candidate housing sites: 

a) Channing-Ellsworth 

b) Oxford Tract 

c) Unit 3 Residence Halls (existing housing) 

d) Smyth-Fernwald 

e) People’s Park 

f) Albany Village, Albany 

g) Bancroft & Oxford 

h) Richmond Field Station 

Can you please explain why the Upper Hearst Development site didn’t make UCB’s RFQ list? 

EECS professor Eli Yablonovitch asserted at the second CEQA hearing that because of the financing difficulties, the parking structure is being torn down to create market-rate housing by an out-of-state developer. “This is not housing that any student can afford,” he stated. Would you please comment on his remark? 

Thank you for your attention. For my conclusions and recommendations, please return to the first page. 

Raphael Breines, Senior Planner 

Physical & Environmental Planning 

University of California, Berkeley 

300 A&E Building 

Berkeley CA 94720-1382b