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8. B. - Page 170 I. RESPONSES TO COMMENTS RECEIVED ON THE FINAL EIR A. RESPONSE TO COMMENTS FROM ADAMS BROADWELL JOSEPH & CARDOZO (LETTER 1), DECEMBER 13, 2011: Comment A-1: We are writing on behalf of fl�e Building a�ld Construction Trades CoL�ncil of San Mateo County to provide comments on the Final Environmental Impact Repoi�t, including Staff's responses to our October 26, 2011 cominents on the Draft EIR, for the 2580 El Canuno Real Residential Proj ect. As described in detail below, the Final EIR does not comply with the reqL�irements of flie Califomia Environmental Quality Act ("CEQA"). The City failed to provide a good faifli, reasoned response to conunents, as required by CEQA. The City's failL�re to provide adequate responses to conunents lea�es potentially sigiuficant impact L�nevaluated a��d tu�nutigated in the Final EIR. The City may not approve the Project until the errors in the EIR are corrected and a revised Draft EIR is circi�lated for public review and conunent. We prepared our comments on the Fu�al EIR wifli the assistance of air qL�ality e�pert, Dr. James Clark. Dr. Clark's conunents a�e attached to this letter as Attachment A. Resuonse A-1: The coinmentor offers no specific basis for its statements that the City failed to provide a good faith, reasoned response to conunents on the Draft EIR so no response is possible. This cominent is acknowledged. The Final EIR does comply with the requirements of CEQA. Comment A-2: L The Final EIR Contu�l�es to Violate CEQA's Requirement to Analyze a��d Mitigate, if Necessa�y, Potentially Significa�lt Impacts; The City Failed to Respond to Public Conunents Adequately. The Final EIR continues to lack sL�bsta��tial evidence upon which to conclude that traffic, air qL�ality a��d pL�blic health impacts are less tha�1 significa��t. The Final EIR also fails to respond to olir October 26, 20ll coimnents adequately a��d fl�ose of our traffic expert, Toin Brohard, and air qL�ality and public health expert, Dr. James Clark. Therefore, a revised Draft EIR must be prepared and circulated for pi�blic review. An agency's responses to public comments ensi�re the integrity of the process by precli�ding stl�bborn problems or serioL�s criticism from beu7g swept under flie rug. Responses to conuilents play such a�1 importa�lt role u1 flie enviroiul7ental evali�ation that the CEQA Guidelules spell out an agency's duty to avoid pro forma responses: In particular, the major environmental issues raised when the lead agency's position is at variance with recommendations and obj ections raised in the comments must be addressed in detail giving reasons why specific comments a��d suggestions were not accepted. There must be good faith, reasoned a��alysis ul response. Concli�sory statements unsupported by facti�al information will not suffice. 2580 El Cainino Real Residenrial Project 2 Response to Conmients Recei��ed on Final EIR Cin� of Red��ood Cin Jannai� 2012