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8.A. - Page 272 <br /> ��I'c'1�.SSBt�'� <br /> ''� �r�v�ro.r,rm�n�rl <br /> -.�. <br /> �*#�TISYIl�1I7� <br /> Ms.Maureen Riordan <br /> 5enior I'Ianner <br /> Planning Departrnent <br /> City of Redwoad City <br /> 1017 Middlefield Road <br /> Redwood City, CA <br /> June 15,2012 <br /> SUBJECT: COMMENTS ON FIIVGER AVENUE RESIDENTIAL I'ROJ�CT FINAL <br /> ENVIRONMENTAi,TMPACT REPORT <br /> Dear Ms. Riordan; <br /> Grassetti Environmental Consuiting (GECo) has been retained by tHe Finger Avenue <br /> Pride Cammittee (FAPC} to review and comment on the Final �nvironmental Impact <br /> Report (FETR} for the Finger Avenue Residential I'roject {Project). In August 20I1 we <br /> submitted comments on the Draft EIR for this project. This letter summarizes the results <br /> of our review of the adequacy of the responses to our DEIR �ornrnents. The comments <br /> herein are based on my review af the DEIR, associated appendices and supparting <br /> documents, and my 30+years af experience preparing and reviewing CEQA documents. <br /> My qualifications were attached to my 2011 DEIR comment letter. <br /> As detailed below, the FEIR fails to correct previously identifiea deficiencies in the <br /> aesthetics and alternatives sections of the DEIR. In addition, in a considerable number <br /> of instances the FETR's respanses to comments fail fo respond to the crux af the <br /> comment, are argumentative, and lacking a basis in fact. As noted in my previous letter, <br /> the document makes a number of critical assurnptions that are not supported by <br /> substantial evidence, and bases its conclusions on those assumptions. My detailed <br /> comments are provided by topic,below. <br /> Inappropriate Project Objectivea Have Resulted in an Inadequate Range of <br /> AlternaHves <br /> As described in rny previous letter, the CEQA Guidelines make clear that the project <br /> objectives drive the agency's selectian of a reasonable range of alternaHves and t�at the <br /> alternatives must meet most of the project objectives and avoid or substantially Iessen <br /> one or more of the project's significant impacts. I previously commenfed that the Project <br /> objectives listed on pp. 20 and 21 of the DEIR {and repeated in the Alternatives section) <br /> are too narrowly defined to allow adequate and meaningful consideratian of <br /> alternatives. As defined, these objectives would limit alternatives that meet all of the <br /> ProjecYs objectives to the Project itself,�s+vhich would be an impermissibly narrow range. <br /> The FEIR's respanses to comments G2 and G-3 assert that c�efining the project objectives <br /> in the CEQA document is solely the discretion of the a�plicant. Using thzs approach <br /> 7008 Bristot Rrive,Berkeley,CA 94705 (5!Q) 854-2354 <br />