AgdaPkt 2012-09-10 - Laserfiche WebLink

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8.A. - Page 362 Finger Ave.Pmject�iR Comments )une 15, 2U12 Page 3 of 12 impaCks of some undisclosed alternative derived frpz�t an undisclosed broader project objertives w'ith thase of the proposed praject and alter�tatives incIuded in the ETR. Despite zero description of either the broader abjectivea or t�t� reataltant alternative, the EIR cancludes, absent any supporting information, that t�te resultant aIternative(s) would not redUCe any of the project's impacts. Fox example, under Impart GEO-4, the respanse states' "Broader objechives would not have influenced the development of aaternatives ta addr�as this ,gea�agy impact as the need for er�sican pmtection aris�s under any circumstance ineiuding exisHng condition." T'his respvnse is incorrect on its face, failing, for example, #o cansider tha#a project with ho�ses set back 54 feet ar more frorn the creek wottld, uiilike the projec# or existing conditions, avoid the erosion and therefore the need far erosion protection. This "analysi�" is thick with these sart of false and unsupported statements masquerading as CEQA analysesi. For example, the discussion of Impact BIO-3, relati�g ko the impacts #o the trees on the project site states, "As discUSSed in the DEIR, npne of the #rees tp be removed....provides a aubstanfial visual contribution to tI1e site or its surroundings and loss of these trees is more #han o#fset by th� projec#'s tandscape p�anting plan.,,.". This response Eai1s to �recognize that neigi�boxs have submitted aver 75 separate statements attest�ng to the va2�e o#the trees and exis#in.g lvw develapment intensity of the site in fhe context af the averal� visval changes ta the proJect, which constitutes eviderice of the significance pf t�te resource asid the patent�al signi#icanc,e of the chaanges to kha#resource. The EIkt's contenfion that small trees planted as perirneter landseaping are visuatly similar to nume=ous�4Q-B(J-fopt tall mature trees flies in the face of coc�mon sense. Five-and ten-gallon landscape trees axe�visual�y qufte diff�rent fro�n the large, maivre oaks and redwoods on the site. The EIK seema ta recognize this weakness in steadfastlp refusing ro provide obJective phatagimulations of the project, which results in the EIR`s condusions being unsupported by substantial evidence, As described below, ather examples of sirnilar unsupported and arbitrary conclUSiona can be found throvghout the document. Project DescripHan Deficiencies We previausly comrnented tl�at a complete, futite, stable pr�ject des�riptian is a prerequisite for an accurace impact assessment and that tlze DEIR Praject Description arnitted a nurr�ber of elements critical to ��euratety and adequately assessing the project's impacts,as fnllaws: 1. A detai�ed starmwater treatment plan,whieh is essential to c�etermining whether the project's impacts to stqrmwater quality and dowristream cumulative flood �azards, as �cvell as whether the project Can be constnected in evmpliance with Kegional Water Qualily Control Baard C.3 skandarda. Note that the RWQCB's regional Stvrmvvater Permits states #hat these plans should be avaiiable for review in CEQA documents (Section C.3 (4.). It is unclear that the projec� can actually meet the RWQCB's Law Irnpact Development(LID) standards giv�n#he density of development prpposed far the site. 2. Blevatians and desrrip�ipn of exterior treatrnent of each of the proposed hauses, which are easential to determining the proje�Ys visua2 impa�ts and tomplian�e wikh general i'fan goals and policies,