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8.A. - Page 456 A. RESPONSES TO FEIR COMM�NTS FROM RYCHARD GRASSETTI, GRASSETTI ENVIRONMENTAL CONSULTING,DATED JUNE 15,2012: Note: The discussion belovv summarizes the primary comments provided in the letter. The letter is at�ached 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/FinaI EIR (FEIR). Therefore,tha responses below are intended ta supplement those already provided in the FETR, cIarifying where necessary responses that may hava been misunderstood by the commentor, and addressing any new issues now being raised. C�MMENT: Inappropriate Project Objectives Have Resulted in an Inadequate Range of A3ternatives. RESPONSE: This comm�nt covers roughly two pages, and cantinues to articulata concerns raised in comments on the Draft EIR that the project objactives are too narrowly defined and therefore have Iimited 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 a�ternatives presented in the DEIR are considered potentially feasible and capable af ineeting most project objactives, other than the No Froject and the Four I,ot 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 farward. 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 commentar that generically seeks "ta develop housing" is not meaningful given the site's current develope� 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 sita's General Plan land use designation, otherwise there would be no ratianale or economic incentive for the project. The main thrust of this comment is that ovariy narrow o6jectives have somehow limited the range of alternatives in a way that has deprived the decision-rnaking process of information that would be crucial ta 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 objecti�es have samehow precluded, and that the decision-makers cot�ld otherwise consider if broader objectives were employed. FEIR Respanse G-3 devotes substantial discussion covering six pages describing how the project's environmental impacts requiring rnitigation (cultural resources, hydrology, geology, biology,visuallaesthetics, and air quality)do not directly arise from the project's size or design (and which are therefore influenced by the objectives), rather these irnpacts result from site conditions which would be affected to some degree 6y any development on the site, and therefore not susceptible to substantial reduction or avoidance by an alternative. The comment suggests that an alternative vvith an increased creek setback"would avoid the erosion attd therefore the need for erosion protection." This is incorrect in that an inereased setback for a house on Lot 3 would ha�e 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 A�enue Nine-Lok PEanned Development Project 2 lZesponses[o FEIR Comtnents City of 12ecfwood City June 2012