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8.A. - Page 367 <br /> Pinger A�e.Project F�1R Comments <br /> June 15,2012 <br /> Page 8 of 12 <br /> Respanse G38 <br /> My origina2 �omment expIaixted in detail how the four-lt�t alternative was designed as a <br /> straw tnan,in#ended to make it iook bad in comparison#a the project. The response (on <br /> FBTR p. ST) tha�t "this atternative was nox deve]oped for the purpose of reducing or <br /> avoiding the project's effecta vr in an attempt to meet most of the praject objectives, <br /> rather this altemati�►e ...is a variation of tl�e No Project Alterna�ive reflecting homes that <br /> could be constnacted on each of the four lots...."[eznphasis in original�, <br /> �CEQA is clear that adternatives are intended ta reduce impacts. To the degree that the <br /> develop under exisHng zoning alternaiive �an retiu�e iumpacts, it is required ta be <br /> designed ta dfl so. CEQA does not exempt t.�,e No Project Alkerz�akzve fram tIZe putpose <br /> of al#ernalives, which is to reduce irnpacts. Fuxfiher, it is clear that, thraugh its CFQA <br /> r�view and desi�n review processes, t}�e City wauld be highly sxnlikelp #o permit the <br /> alternative as described in the EIR and,therrefare,the statement that it would be diffiCUtt <br /> �ar staff to implement the rzutigations/design �eatures identified in my previous <br /> comxnent is speculative, at best {and mnre like�y false). This version qf the no-project <br /> alternative is nat consistent with CLQA requirements far alternaiives. <br /> Respanse G-39 <br /> Th�a response again uses the irnpermassibly narrow projeet objectives to fznd the 4-unit <br /> project irifeasibte. See my earlier�ammenta regarding these pbjeckivea. <br /> Reaponse G-40 <br /> The original carnment qUest�oned why the 4-Ivt alternativea A and 8 didn't inclvde <br /> smaller houses that would reduce the project's impac#s tv visual qualiky, runoff, and <br /> mature trees, The respanse that, "'I'he DBiR does nat disclose that #he house sizes <br /> themselves result in significant impacts tequix'ing rnitigatian or that warrant <br /> mnsideratioa in alternatives" is nonaenaical. The DBIR does acknowledge that <br /> increased impervious surfacea cauld produce increased quantities of contaminated <br /> r�noff co�npared to exist�ng conditions if not proper�y contralled and treated. Furthe�, <br /> the EIR acknowledges that the praject intensity of develapment wouid �hange the <br /> aesthetic character of �e site, and the significance of this change is supported by <br /> nurnexaus cazz►znen#s from �ocal residents. This is evidence enoUgh tl�at smaller houses <br /> (wit� smaller footprints, less visual prominence, and �ess tree rernoval} yvould reduce <br /> impacts. This altemative continues to fail to meet basic CEQA purposes for al#ernafives. <br /> Response G-41 <br /> This response �ontintaes to say that 9 sm�ller houses "are likely to set2 for lesa.,.which <br /> cauld affect project feasibiliiry", This sfatement, as with the original pEIR stakement, is <br /> atill entiraly unsupported by fact. The �1R prcavides no eviden�e as to what level Qf <br /> development ia financial(y feasible or infeasible. Just because there could be less profit <br /> (althaugh even this is specutative, as smaller homes presnmabty would cast Iesa to <br />