AgdaPkt 2012-09-10 - Laserfiche WebLink

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8.A. - Page 360 � ��1�a��5'cB�t� s�`�r�v�'r o r x r�e n�r I � ��::�nSUl��i�g Ms.Maurecm Riardam Senivr Flanner Planning Deparhnent City of Redwnnd City �0]7 Middlefield Road Red�vood City, CA Jvne 15,2D12 SUBJECT: COMMENTS�N FINGER AV$NUE RESIDENTIAL PRC7J`$CT FINAL E]VVIRONMEN'I'AL IMPACT REPQRT Dear Ms.Riordan; Grassetti Environmenta] CvnsuIting (GECo) has been retained by the Fingex Av'enue Pride Cornmittee (FAPC) to re�view and camment on the l�ina2 �nvirarunental Impact Keport (FEZR) fox the Finger Avenue Residential 1'�raject (ProjecE). In August 2011 we submitted wrnments on#he Draft EIR for this project. 'I'l�is]etter surnrnarizes the results of aur review of the adequac� of the respanses to our DEIR commeYtts. The camments herein are based on rny review of the DEIR, asso�iated appendic�s and supporting docurnents,and my 30+years of expezience preparing and reviewing CEQA doruments, My qualifications were attached to my 201� DEIR comment]etter. As detailed below, the FEIR fails to correct previously identified deficiezi,tles in the aesthetics and alternatives seelions of the DBIR. In addition, in a considerable nurnber of instances ti�e FEIR's respan�s to comrnents fail to respond ta the crux of the comment, are argumentative,anci lacking a basis in#act. As noted in amy previous letter, the document rnakes a number of critical asaurnptions that are not supported by substantial evidence, and bases its conclusians on those assumptions. My detailed camrnents are provided by topic,belovv. Inappropriate Prnject Obje�tives Have Resulted in an Inadeqnate Itange uf Alternatives As described in my previeus letter, the CEQA Guidelines rnake c�ear that the project objectives drive the agen�y�'s selection of a reasona$le�ange of alternatives and ti�at the alterna#ives must meet most af the project obfect�ives and ava�d or substantiatl� Iessett one or more of the project's significant impacts. I previously commented that the Project objectives listed on pp.20 and 21 af the DEIR (and repeated in the Alternatives section) are tvo narrawly de£ined to allow adec�uate and meaningful c1onsideration of alternataves. As defined, these abjectives would Iimit alternaiives that meet all of the Project`s abjectives tc�the Project itself,which wouId be an imperrnissibly naxrow range. The FEIR's responses to comrnents G2 and G-3 assert that c�efining the project objectiv�ss in the CEQA doct�rrtent is solely the discretion af the app1iC21nt, Using this approach 7008 Bristol Rrive,Berketey,CA 94705 (5!0)859-2354