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8.A. - Page 363 Finger Ar+e.Praject FEIR Comments June 15,2012 Page 4 of 12 3. A map showing pervious/impea'vious surfaces bath with and without the praject, which is essential to d�#ermining the adequacy af the rtxnaff Calculations and associated requis�te stormwater treatrneni�faciliHes. 4. A description of the actual pnoposed Lot 3 erosion protection plar�. This is essentaa�to the EIR being adequate for CDFG's review of that p2an, as well as for the p�rblic/decisian-makera' review of potentia[ project impacts to Cordi�)eras Creek. 5. Figures 2.Q-I and 2A-2 shauld be expanded to show the acijacent residences,so it is possible ta clearTy see the relationship of the Pxaject and adjace�tt residences, This is required to understand the project's ?and use, aesthetic, and noiae irnpact�. Also, these figures shou�d be in Chapter I, as they pertain to the project description. In response, the FEIR in�udes axt uru�eadable "drainage glan" that faii� to show stormwater treattnent, capacikies, pre- or post- pxaject discharge rates into the creek, f�ow the project would comply wifh I,IQ reyuirexnents, and fails entirely to provide house e�eva#ions, a map uf s�arface perrneability,the I.ot 3 erosion protectian plan,or the project in the context a#the adjacent residencea. In respvnse to my comment that the first bullet on p. Z2 prohibits impervious surfaces within 15 feet of the top of bank and that the prapased 15-2� fao� "no-build" easements do not appear ta�onforrn to the City's 25-foot aetback req�irements the FBIR (Response G-�7)goes off on a tangent and fai�s to respond to substance of the comment. TechnieaI Anal�sis Deficiencies I previously provided detailea cvmments regardirig technica� deficiencies in the DEIR. AIfhough some of our wmments have been adequately addressecl, a number af aubstantive deficiencies identi�ied in our carnments rernain. These are generally disrussed below. Responses G-2�and G-22 These resgvnses purpoart ta addreas deficiencies in the EIA in descz7ibing and assessing impacts on water quality. The cor�eern of the comments was that the incxeased impervious surfaces, increased develapment, and inCreased traffie would increase both downstrearn flooding and tF�e discharge of pollutants into the adjacent creek. In essenc� these respqz�ses claim that the project's stormvva#ez system wii] 1) direct all potentially pol�uked runoff to a detention and treatment system beFore discharge into the creek, and 2) the project won't increase peak z�unaff or pvllt�tion in the creek. The problem wikh these responses is that the EIR pravides no evidence of the feasibility a# adeguate treatment. This is not rnerely an acadernic issue--given the site's ve�'y high c�ensity of develogment, it is uncIear t�at effective treatment of runoEf of pvllutani� �rorn large areas af impervious surfaces through �.ID methods is acivally feasib7e on #he site. Simplq stated, there may nat be roqm for treatment and the EIR provides no evidence af its feasibility.