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8.A. - Page 148 <br /> o What will prevent drivers far using their neighbors' driveways as turn <br /> arounds at �he ex�.d of the divided road, rather than driving all the way to <br /> the proposed cul-de-sac? <br /> 3. AVERAGE SLOPE MEASUREMENTS ARE CRITICAL BUT REMAIN <br /> UNCLEAR <br /> • Given the zoning restrictions for hillside development and the obviously fragile <br /> nature of the steeply sloped lots, average slope measurements for all building lots <br /> is critical to the EIR analysis as well as the projec� application process. Yet, we <br /> have little confidence that the average slope measurements on the record are <br /> correct. You will recall, fox example, in the De.cember 7, 2410 staffreport, sZope <br /> measurements submitted by the applicant (BKF Engineers) and by the planning <br /> staff were significantly different. Spot checking by an experienced community <br /> member showed that the staff ineasurements were closer to the rnark and that the <br /> applicanf understated �he slope measurements. (See atta.ched camments by Bruce <br /> 5torm). Curiously, the Notice of Public Hearing for this EIR appea.I describes the <br /> average slope measurements using the applicant's numbers ("from 22 percent to <br /> 38 percent"). And the August $ staff report for this hearing incorrectly describes <br /> the site's average slopes as being up to 40%. How ar�d why is this happening? <br /> 4. VEGETATION MITIGATIOIV MEASURES ARE EXTREMELY DIFFICULT TO <br /> IMPLEMENT, MONITORAND ENFORCE <br /> I agree with the staff report's canclusion that geological mitigation measures may <br /> indeed be infeasible and therefore inapplicable. In fact, most if not all the <br /> mitigation measures adopted by the Planning Cammission are extremely difficult to <br /> implement, require intensive and continuous monitoring, and have no hope of being <br /> enforced. Mitigatian measures affecting vegetation aptly demonstrate this key <br /> inadeyuacy of the EIR: <br /> • Establishing and maintaining native plants isn't easy. Native grasses <br /> especially are hard ta establish & maintain. Is it realist�c to expect the <br /> praperty owners to be able to continue to comply over the long term? <br /> Su�sequent bu}rers? Will the City (or another group?] be able to provide <br /> sufficient initial and on-going education to assist homeowners in complying <br /> with the mitigation requirements? <br /> + Who will monitar effectiveness af the mitigations once proj ects are done? <br /> • The proposed plant list includes some plants that failed to survive [on <br /> properties near the site) due ta repeated damage by deer. These include: <br /> Ceanothus, sp, Fremontodendron sp, Heteromeles arbutifolia, Gercis <br /> occidentalis, etc). <br /> + Oak/grassland corrtmunities are complex. Is the definition of tree "health" <br /> suFficient�y braad to take this complexiry into consideration? Is it necessary <br /> to remove as many oaks/laurel as proposed? One criteria the consultant <br /> used ta define trees in poor health was "leaning." Yet many healthy oaks <br />