Re. "Commentary: It's time to revitalize the Peninsula Zone,": (Jan. 23): The author correctly describes the condition of the patient, urban decay. However, the author then incorrectly diagnoses the cause of the condition as the result of City Council neglect or poor city planning. Not surprisingly, this leads to an incorrect conclusion: the entire Peninsula zone will be significantly improved if the council just chooses the right development plan for the old City Hall site.

Without foundation, the author writes, "authorities sadly neglected the area for the priorities of more commercially popular and newer developed areas round Fashion Island," where planning was assisted by Irvine Co. planners.

For this statement to be correct, the city must possess legal authority to make changes to the Peninsula zone. In fact the city has limited power to make any significant changes to a land-use pattern existing almost unchanged for more than 50 years. All city governments' land-use authority over developed land is limited to zoning issues such as parking, signing, etc., unless a redevelopment agency was formed. Redevelopment agencies have now been eliminated by state law and, prior to this event, the chance of the local voters approving such an agency would have been less than slim or none.

The author presents no reason for reference to Irvine Co. land planners. In any event, a comparison of large-scale development land planning to city planning is the same as comparing apples to oranges. Planning options for the development of large areas of single ownership land simply do not have the same constraints as local city land planning. In fact, about the only real similarity is in the word "planning."

The actual reason for the commercial decline in the Peninsula zone is simple: The existing commercial space is no longer in demand. Demand for retail space is generated by consumers' demand for the products to be sold in the space. When the area was originally developed, shopping occurred in small neighborhood centers at small shops. This is no longer the case.

The customer base of these shops has moved to regional malls, big box retailers, large chain restaurants, etc. What remains are a few convenience stores, such as cleaners, drugstores, etc. Absent the ability to consolidate smaller land ownership into parcels more suited to changing retail use, local authorities do not have the tools to deal with demand changes.

The author concludes the city leaders have the chance to rehabilitate the entire Peninsula zone by correctly deciding how to reuse the old City Hall site. It cites two reasons for this conclusion: 1.) "A rising tide lifts all boats" and 2.) The pier and South of Market area were upgraded by the city of San Francisco.

The author presents nothing to substantiate its claim the large amount of vacant retail space will be buoyed by a new use at city hall, and ignores the vast comprehensive efforts (which made extensive use of urban redevelopment funding) made by San Francisco, which are not available to our city.

The disposition of the existing city hall site is an important issue. If redeveloped into high-density residential space, it will generate some level of demand for local service retail. If the parcel were to be combined with some of the contiguous parcels, creating a single large parcel, a viable mixed use residential retail development could replace some of the vacant space. However, it is unfair to our elected representatives to suggest that somehow making the right decision would revitalize the Peninsula zone.

STEVEN H. STRAUSS lives in Corona del Mar.