AgdaPkt 2011-08-22 - Laserfiche WebLink

Browse Search

manatt $�A. - Page 125 menatt � phelps � phillips Honorable Mayor and Members of the City Council August 15, 2011 Page 14 Enviranmental Impact Analysis, 3.1 Aesthetics.} Thus, while �nit�gation rneasures a#empt to address isolated objectionable impacts, they do not capture the cumulativic effect of S-plus years of these ongoir�g adverse conditions. It is a foregone conclusion that some neighbars, particularly those households with elderly residents and children will quite Iiterally be farced from their homes as a result of increased traffic, noise, reduced air quality, risk of landslides and the c;onstant presence of heavy construck�on equipment. Yct, the FEIR brazenly states that no residents vcrill be disp�aced as a result of the project. Given the sheer size, length an� close �roximity of t1�e project �o existing hames, this statennent simply begs credibi3ity. � Perhaps most concerriing is the Staff Report's discussion of the potential infeasibility of some or all af the Mitigation Measures ac�op�ed wlaolesale by the Planning Conamission. Even assuming the adequacy of such measures, the cost of implementation and �nforcemenf (to be borne by the applicant) wil� be enonnaus. 1'h� applicant has already pointed out that such costs are an issue relative to home resale value. Before certifying this EIR., tl�e City should determine whether such casts are prohibitive, and wl�►ether the mifigation measures are, in fact, infeasible. (e} The EIR Fails to Descri6e A Reaso�uable Ran.�e of Alternatives to the PrQiect CEQA rey�ires thai ar� EIR must discuss a reasonable range of altematives to the pmpased project ar its locatian that would feasibly me�t most project objecti�ves but avoid or substantially lcssen the project's significant iinpacts. (CEQA Guidelines, § 15126.b.) Due to the incor�rect and inadeyuate im}�act analysis and insufficient mitigation measures, the alternati�es praposed necessarily f$il to present real alternatives to the under-described environmerital desh proposed by the praject. Alternative B, for exarnple, cal�ing for slightly reduced building squate footage, keeping all other aspects of the praject the same, would have no overall positive effect. Further, we txnderstand froin the Staff report that coinparison house size data (Appendix C ta the Final EIR, on which Alternative B is based} is significantly flawed and no substitute data have been adapted. We wou�d alsa like ta point out that the "r�o project alternative" (Alternative A) is not necessarily likely to produce a greater envirorune��tai impac� than thc planned development project. If the � The Commission's blanket denial of the existence of any significant environmental impacts resulting froin the proposed development gives the unfortunate appearance of subordinating che interesis of the nearby commuivty, long-term residents, and the environment to autsized de�elapment, which wc do not believe khe Commission intended.