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8.A. - Page 275 Finger Ave.Project FEIR Comments June 15,2012 Page 4 of 12 3. A map showing pervious/impervious surfaces both with and wifhoUt the praJect, which is essential to determining the adequacy of the runoff calculat3ons and associated reyuisite stormwater treatment facilities. 4. A description of the actual proposed Lot 3 erosion protection plan. This is essential to the�IR being adeyuate for CDFG's review of that plan, as well as far the public/decision-makers' review af potentiaY project impacts to CordiZleras Creek. 5. Figures 2.Q-1 and 2.0-2 should be expanded to show the acijacent residences, so it is possible to clearly see the relationship of the Project and adjacenf residences. This is required to understand the projeet's land use, aesthetic, and noise impacts. Also, these figures should be in Chapter 1, as they pertain to the project description. In response, the FEIR includes an unreadable "drainage plan" that fails to show stormwater treatment, capaciHes, pre- or post- project discharge rates into the creek, how the project would comply with LID requirements, and fails entire�y to provide house elevations, a map of surface permeability, the Lot 3 erosion protectian plan, or the project in the context of fhe adjacent residences. In response to my comment that the first bullet an p. 22 prohibits impervious surfaces within 15 feet af the top of bank and that the praposed 15-20 foot "no-build" easements do not appear to conform to the City's 25-foot sefback requirements the FETR (Response G-x7)goes off an a tangent and fails to respond to substance of the comment. TechnicaI Analysis Deficiencies I previously provided detailec� camrnents regarding technical deficiencies in the DEIIZ. AIthough some of our comrnents have been adequately addressed, a number of substantive c�eficiencies identified in our comments rernain. These are generally discussed belo�v. Responses G2� and G-22 These responses purport to address deficiencies in the EIR in describfng and assessing impacts on water yuality. The �oncern of the comments was t}►at the increased impervious surEaces, increased developmsnt, and increased traffic wauld increase both downstream flooding and the discharge of pollutants into the adjacent creek. In essence these responses claim that the project's stormwater system will 1) direct all potentially pollutea runoff to a detention and treatment system before discharge into the creek, and 2) the project won't increase peak runoff or pollution in the creek. The problem with these responses is that the EIR provides no evidence of the feasibility of adequate treatment. This is nat merely an academic issue — given the site's very high density of development, it is unclear that effective treatment of runoff af po�lutants frnm large areas of impervious surfaces through LID methods is actually feasib�e on the site, Simply stated, t�ere may not be room for treaiment and the EIR provides no evidence of its feasibility.