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8.A. - Page 278 <br /> Finger Ave. Praject FEIR Comments <br /> June 15, 2012 <br /> Page 7 of 12 <br /> is why most CEQA documents on projects with potentially significant visual impacts <br /> include them. For example, the City of Belmont is current�y using a set of 3 such <br /> simulations in an Initial 5tudy on a lOQ-foot roaaway extension and a sin�Ie 2,500-sq, ft. <br /> house. 'Fhese simulations are essential to supparting any conc�usions on the project's <br /> visual imgacfis. <br /> In response to the City's refusal to include this critical information, local residents <br /> contracted to prepared simulations themselves. These sirnulations, submitted by the <br /> F'APC under separate cover, indicate a significant change in �he site's visual quality, <br /> consistent with the concerns aver adverse aesthetic impacts described above. <br /> Failure to include these simulations in the �TR is a substantive failure on the part of the <br /> Lead Agency. The response should be revised and EIR should be recirculated given the <br /> new simulations. <br /> Responses G-33 and G-34 <br /> The response correctly identifies the issue of significance with respect to aesthetic <br /> impacts as related to the number af viewers. The respanse then focuses on private <br /> views "of a dozen or so" nearby residents. This campletely ignares the gist of the <br /> comment, v+rhi�h r�vas that t�e significance of the impacts ignored t'he combination af <br /> pubiic and prti�ate r�iezus, and therefore is similar to the Ocean Vzew EsEates confext. <br /> Further the response fails to consider the opinions of over 751oca1 residents who signed <br /> staternents specifieally expressing their cancern with the aesthetic impacts of the project. <br /> This failure, in carnbination vvith the lack of substantial eaidence of lack of significance, <br /> as discussed with respe�t to Response G-26, above results in a failure to adequately <br /> address this important subject. <br /> Response G-34's conclusion that the EIR aesthetics analysis assessed the impact of <br /> combined impacts of all elements of the pxoJect is entirely unsupported. The referenced <br /> canclusion that the praject "would reinforce the de�eloped character of Finger <br /> Avenue...rather than the semi-rural aesthetic° on the north side of Finger merely states <br /> the obvious, but does not evaluate the significance of that change as mandated hy <br /> CEQA. It does, however, support the local residents' contention of a significant impact <br /> due to the loss of the semi-rural character (the significance of which is never evaluated <br /> in the EIR). <br /> Response G-36 <br /> The response continues to claim, in the absence of any st�pporting evidence or anaIysis, <br /> t�at exis#ing st�ructures on the site wonld be likely to fail in an ear#hquake. In £act, as <br /> nated in the comment, the structures apparently sut�rived the 1906 Magnitude 7.8 <br /> earthquake. It further ciaims that retrofitting efforts "are likely to be substantial and <br /> expensive", again in the absence of any supparting information vr economic ana�ysis. <br /> Given that in this neighborhood, tear-downs and recanstructions are considered <br /> feasible, alt of these claims of expense leading to infeasibility are speculative, at best. <br /> CEQA does not permit speruIation. <br />