Basing environmental impacts on a reasonable set(s) of data would seem to be the core basis and reason of an Environmental Impact Report to begin with. The report should strive to be objective and balanced, however, when the interests of developers and municipalities intersect, it seems as if the process can get circumvented or shortchanged. Take for example the “less than significant impact” conclusion that the Transit Village EIR draws regarding visual impacts.
The excerpt from the report below shows that only 6 locations in the community were sampled for visual data to make the “less than significant impact” conclusion.
To demonstrate impacts specifically from the proposed project, photographs of the existing site and simulations of the proposed project are provided in the following impact analysis. The simulations of the proposed project have been prepared from six vantage points that represent views from sensitive viewer locations relative to the project site and from vantage points that have been identified as areas of concern during the scoping process for the project. Figure 3.3-8 depicts the six vantage points, which are illustrated in the corresponding figures. Visual simulations for the projected views depict the proposed building massing, scale, orientation, architectural design, and landscaping.
As you can see from Figure 3.3-8 below – two locations from Old County, two locations from El Camino, one location on Vine Street and one location from Laureola Park were used to make this determination.
The EIR states on page 3.3-11 that:
Figures 3.3-5 and Figure 3.3-6 provide representative views from northeast San Carlos, looking westward from Old County Road and Riverton Drive, and Old County Road and Sylvan Drive, respectively.
Here are the pictures taken from the EIR that claim to be representational samples:
This view from Riverton makes it seem as if the Pulgas Ridge doesn’t even exist for residents living on that street! The picture is taken on the north side of the street and is a southwestern angle.
This shot from Sylvan maximizes the view of the trees and minimizes the view of the hills.
I mentioned in my previous post about before and after shots about how the picture taken from Laureola Park minimizes the visual impact of the project from Laureola Park.
Here is the shot once again:
These shots are used as a justification for the conclusion in the EIR that the project “would not substantially degrade existing character or quality on site, at sensitive viewer locations, or along scenic roadways.” and that the “Cumulative impacts on visual quality would be less than significant.”
VQ-3. Degradation of Site and Surrounding Visual Character. The proposed project would not substantially degrade existing character or quality on site, at sensitive viewer locations, or along scenic roadways. LTS None required. N/A
VQ-5. Cumulative Visual Impacts. Cumulative impacts on visual quality would be less than significant. LTS None required. N/A
The sample locations taken in the EIR minimize and misrepresent the visual degradation and impacts to the neighborhood.
Therefore the conclusions that there are no mitigations needed regarding visual impacts are incorrect.
Mitigation plans need to be added to address the loss of visual quality and character to both east and west side residential communities adjacent to the site.
There isn’t a single sample taken further down any of the streets of Northwood, Riverton, Inverness, Sylvan, Springfield and there are no samples taken from the intersections of those streets with Fairfield.
There are also no samples taken that would show the impact of buildings 6,7, or 8 for any locations south of Holly street other than the one shot from Laureola Park that I described in a previous post.
There are also no samples that would show the effect of the buildings on West side residents other than Figure 3.3-7 – the view from Pulgas Ridge which is shown below.
There are no samples showing the deleterious effects on views from the Caltrain platform which I also outlined in a previous post.
From the EIR:
• Figure 3.3-7 illustrates views of the project site and the surrounding area from the hillsides of the Pulgas Ridge.
No other locations were used for West side residents whose view of the East Bay hills will be affected by this project.
I take walks up those hills frequently and will bring a camera along soon once the weather allows, but I do have a few shots of the North East Side neighborhood that show a decidedly different representation of the Pulgas Ridge hills than is represented by the EIR:
In the GESC Associations opinion, the conclusions drawn based on an undersampling of impacted areas not only for east San Carlos but also for west San Carlos seriously undermine the veracity of the EIR and they completely undermine its “less than significant” impact conclusions.
If this was an isolated occurrence in the EIR it would be one thing, but there are multiple instances where this minimization of impacts occurs regarding numerous other issues. These significant shortcoming in the EIR document are very troubling.
For example take a close look at figure 3.3-8 below. Notice that the project site stops at El Camino and San Carlos Avenue. The parking lot south of San Carlos Ave where Building 8, the 47 foot high Office and retail structure, is located is not part of the project.
We only have until Monday to report our findings with the EIR. I feel that a full time team of experts is needed to uncover all of the issues in the document and it is unfortunate that the burden of resposibility lies with the residents of this community and not with the city staff which should have reviewed the EIR and asked for corrections before claiming it as ready for draft status.