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8.A. - Page 362 <br />B.A. - Page 120 <br />111421 1+E d <br />ffwmft I ~ IphNP <br />Honorable mayor and Members of the City Coumcil <br />August 15, 2011 <br />Page 9 <br />derasitmmakers with information which ambles then to make: it dc6sioa w111ch intelligWUY <br />W= account of environmental exrmogt .,:' (San JWgw1n Raptar Resetre M v. Coenty of <br />Merced (2DD7)149 Cal.App,4th 645, quoting CEQA Guidelines. $15151.) The 1E3IR fails to <br />cmVly with these mandatory requires. <br />The prajec is significant impacts are gravely undmwtimated wizen oomparcd to the baseline <br />thresholds. Purthmnore, there are additional unidentified gignificm t wiveme impacts and <br />cumulative impacts overlooked by the MR. Notwithstanding the #fit dW siW&ant advww <br />impacts are tmde =titrated or overlooked, the "mitigati(m rctr; w=n poposed to reduce <br />actc181131identifie . impacts woefully inadequatr, u we;alistic and impractical - <br />Examples oftbe HIR's Wal defidencies include five following:2 <br />According to Geology and Hydrology zaports provided by the CitY= saveral <br />critical measures tarcessary to evaluate the potentially significant environmental <br />impact$ of the project have not yet been undertaken. These include, but are not <br />limited to, grading and improvement plane, a detailed &csion Control plan, a <br />Storm Wates Pollution Pmvention Plan, a Spill Con6npzrY and Countmmawam <br />Plan, as evaluation of an existing landslide on Lois 3 and 4, and other c'itical <br />h dlo such as t=gmtsty excavation support plum, detailed foundation <br />explorations and gooteeimioal investigations on each lot. (See MP, Appendix <br />A: Mitigation Mowtofiag and Reporting Program; Resolution, Exhibit A, pp -11- <br />20) <br />o poliely available raporh of ne:atby Mercury mining activity have: not boon <br />analyzed, nor have soil toxicity tests for nx ncury and attendant poIlutOts been <br />perfbrmed. This 9=rts to have been a particularly concetuing ovmligbt Sven <br />that at twat one mam ry mina was operatioeal in the ovk a decomposing oil <br />dn= was located on site, and there is substantial evidence of seapa in &e same <br />vicinity. <br />Many oomments on the DEIR noted serious concern that proposed girding end <br />exauvadon would des;tabilixo the billsidc and advemly impact adjawd <br />residences and the: existing creels. Theme is rw substantW evidcarce iA the r=rd <br />e Tiro list of noted de#`r twin is wt exbswaim and is based on u xaview of to pmvim* submitted (now <br />p 4vot pwpesal. The cvideoee F=a*d m based an up a 8nee bath eapwbo sod nonce, <br />is kftg die pw@=1 obwodow cnd past esperiewe ofam roddcat& Ilse mead of LWANA live sod Own <br />p vpcz y in ttye vietniq+ of the pro jest site, acid lave direct knowledge of the tnVk=M W c "abate of the atte. <br />