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8.A. - Page 368 A. RESPONSES TO FEIR COMMENTS FROM RICHARD GRASSETTI, GRASSETTI ENVIRONMENTAL CONSULTING, DATED JUNE 15, 2012: Note: The discussion below summarizes the primary comments provided in the letter. The letter is attached in its entirety in Attachment 5 of the City Council staff report. In many cases,issues are raised that have already received a detailed substantive response in the First Amendment/Final EIR (FEIR). Therefore,the responses below are intended to supplement those already provided in the FEIR, clarifying where necessary responses that may have been misunderstood by the commentor, and addressing any new issues now being raised. COMMENT: Inappropriate Project Objectives Have Resulted in an Inadequate Range of Alternatives. RESPONSE: This comment covers roughly two pages, and continues to articulate concerns raised in comments on the Draft EIR that the project objectives are too narrowly defined and therefore have limited the development of the EIR's range of project alternatives, for which detailed responses were provided in the FEIR, see in particular Responses G-2 and G-3. It should be clarified that design alternatives presented in the DEIR are considered potentially feasible and capable of ineeting most project objectives, other than the No Project and the Four Lot R-1 Zoning Alternative,which is a variation of the No Project Alternative by describing what development is likely to occur given the site's R-1 zoning should the Planned Development project not go forward. The project objectives reflect the private development application filed with the City,which seeks to redevelop a site that currently has six dwelling units with a nine unit subdivision. A broader statement of objectives as suggested by the commentor that generically seeks "to develop housing" is not meaningful given the site's current developed condition. Rather, it is inherent in the project's underlying purpose that the site redevelop in a more intense manner with additional units consistent with the site's General Plan land use designation, otherwise there would be no rationale or economic incentive for the project. The main thrust of this comment is that overly narrow objectives have somehow limited the range of alternatives in a way that has deprived the decision-making process of information that would be crucial to considering development of the site in ways that substantially avoid or reduce environmental impacts. However,this appears academic, as the commentor has not suggested any additional alternatives that the purportedly overly narrow objectives have somehow precluded, and that the decision-makers could otherwise consider if broader objectives were employed. FEIR Response G-3 devotes substantial discussion covering six pages describing how the proj ect's environmental impacts requiring mitigation (cultural resources,hydrology, geology,biology,visual/aesthetics, and air quality) do not directly arise from the project's size or design (and which are therefore influenced by the objectives), rather these impacts result from site conditions which would be affected to some degree by any development on the site, and therefore not susceptible to substantial reduction or avoidance by an alternative. The comment suggests that an alternative with an increased creek setback"would avoid the erosion and therefore the need for erosion protection." This is incorrect in that an increased setback for a house on Lot 3 would have no effect on the rate of erosion, and the need for mitigation under Impact GEO-4 is to halt loss of rear yard area,not to protect the house itself Finger Avenue Nine-Lot Planned Development Project 2 Responses to FEIR Comments City of Redwood City June 2012