November 4, 2009

Second and PCH Comment Letter (NOP)

Following are the pertinent portions of the comment letter I drafted and sent regarding the proposed Second and PCH Project in response to the Notice of Preparation (NOP)/Initial Study:
  • Given the likelihood of significant traffic impacts associated with the proposed Project, feasible mitigation will be necessary to reduce said impacts to below a level of significance. Such mitigation should not include extension of either Shopkeeper Road or Studebaker Road as doing so would cut a road through the wetlands, and would also have associated environmental impacts. Should extension of either road be identified as traffic mitigation for the Project, however, impacts of the road extension(s) must be analyzed in the Project Environmental Impact Report (EIR).
  • For consideration of compliance with SEADIP's 30% usable open space standard, only "on the ground" aspects should be included in analyzed calculations, being mindful that "building footprint, streets, parking areas and sidewalks adjacent to streets" shall not be considered usable open space. Whereas the Project contains both "above ground" and "private" open space, these areas should not factor into the equation when determining usable open space under SEADIP.
  • It is my understanding that the Project will also include approval of a Development Agreement (DA). Aspects contained within the DA should be analyzed in the EIR. For instance, if the DA is to include off-site improvements such as landscaping (either adjacent to, or even on, the wetlands), the EIR must identify and analyze the potential direct and indirect impacts associated with this (and any other) surface disturbing activity.