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<br />In response to my question concerning this point, Mr. Gregg <br />Downing, Environmental Review Coordination wrote: <br /> <br />"...the AUAR process can be used to review 'residential, commercial, <br />warehousing, and light industrial' development (and associated <br />infrastructure). We historically have treated these as different types of <br />land used, each with somewhat different set of potential environmental <br />impacts... According to subpart 3 of the AUAR rule, the RGU's order <br />for the AUAR must include the 'anticipated nature, location, and <br />intensity' of each of these 4 types as an aggregate. Further, as subpart <br />7, items C and D refer to 'maximum development levels' using the <br />plural 'levels,' not the singular 'level.' We believe this is a clear <br />reference to the 4 different types of land used.... If the total aggregate <br />development was meant, the word [levels] would be singular." <br /> <br />"Another reason we think that each of the 4 types is to be considered <br />separately is that if they were to be considered in aggregate the rule <br />would need to specify some sort of formula for equating, for instance, <br />residential units with commercial floor space.... Without a basis for <br />comparing the units, the offset idea can only be applied in a very <br />general, qualitative way which we do not see as sufficient for <br />determining if a substantial change in the development assumptions has <br />occurred. " <br /> <br />"For these reasons, ...we have always compared two or more <br />development proposals on a land use by land use basis, ...." <br />