AgdaPkt 2012-07-09 - Laserfiche WebLink

Browse Search

8.A. - Page 274 Finger Ave.Project FEIR Cornments lune 15, 20I2 Page 3 of 12 impacts of some undisclosed alternative derived from an undisclosed broader project objectives w'ith those of the proposed project and alternatives included in the EIR. Despite xero description of either the broader abjectives or the resultant alternative, the EIR canc2udes, absent any supporting information, that the resultant alternative(s) would not reduce any of the project's impacts. For example, under Impact GEO-4, the response states' "Broader objectives would not have influenced the developrnent of altexnatives to address this gea�ogy impact as the need for erosion protection arises under any circumstance including exisfing condition." This response is incorrect on its face, failing, for example, to consider that a project with houses set back 5D feet or more from the creek would, unlike the project or existing conditions, av�oid the erosion and therefore the need for erosion protection. This "analysis" is thick with these sart of false and unsupported statements masquerading as CEQA analyses. For example, the disctission of Impact BIO-3, relating to the impacts ta the trees on the project site states, "As discussed in the DEI1Z, none of the trees to be removed,...pravides a substanfial visuat contribution to the site or its surroundings and loss of these trees is more than offset by the project's landscape planti�ng plan....". T'his response fails to recognize that neighboxs have submitted over 75 separate statements attesting to the value of the trees and existing low development intensity of the site in the context of the overall visual changes ta the project, �nrhich constitutes evidence of the significance of the resource and the potent�al significance of the changes to that resource. The EIR's contention that sma11 trees planted as perimeter landscaping are visually simzlar to numerous�Q�80-faot tall mature trees flies in t�e face of common sense. Five- and fen-gallon landscape trees are visually quite different from the targe, mateire oaks and redwoods on the site. The EIR seems to recognize this weakness in steadfastly refusing to pro�ride objective photosimulations of the project, which results in the EIR`s conc�vsions being unsupported by substantial evidence. As described below, other examples of similar unsupported and arbitrary conclusions can be found throughout the document. Project Description Deficiencies We previausly Commented that a complete, finite, stable projeet description is a prerequisite for an accurate impact assessment and that the DEIR Praject Description omitted a number of elements critical to eccurately and adequately assessizlg the project's impacts, as follows: 1. A detai�ed stormwater treatment plan, which is essential to determining whether the project's impacts to stvrmwater guality and downstream cumulative flood hazards, as well as whether the projec# can be constructed ir� compliance rnrith Regional Water Qualiiy Control Board C.3 standards. Note that the RWQCB's regianal Stormvu'ater Permits states that these plans should be available for review in CEQA dacurnents (Section C.3 (4.). It is unclear that the project can actualty meet the RWQCB`s Low Impact Development {LID) standards given the density of development proposed for the site. 2. Elevations and description of exterior treatment of each of the proposed hvuses, which are essential to determining the project's visual impacts and compliance with general l'lan goals and policies.