Neighbors for Wintersburg Wetlands Restoration

1
Neighbors for Wintersburg Wetlands Restoration
2
The NWWR Vision

• Acquisition and Re-integration with the Greater
  Bolsa Chica Ecosystem
• Restoration of the wetlands, functioning as a
  Natural Treatment System, Flood Buffer, and
  Wildlife Habitat
• Filtration of urban runoff that would otherwise
  flow into Huntington Harbour

3
IRWD Treatment Wetlands

• Type I -- Offline
• Type II -- Inline
• Type III -- Co-located Within Detention Basins

4
The Shea Parkside VisionIll-Conceived and
Poorly Planned

• Loss of wetlands
• Increased traffic problems
• Increased flood threat
• Increased water pollution
• Threat of home damage by subsidence
• Fire response deficiencies
• Numerous other concerns

5
Its Really a Wetlands!

• Three parameters for wetlands delineation
• Hydric soils
• Hydrophytic vegetation
• Consecutive days of ponding water
• This property exhibits all three. The Coastal
  Commission only requires just one!

6
Coastal Commission July 3, 2001 letter

• Though the area may have contained wetlands in
  the late 1980s, the DFG (March 16, 1998)
  concurred with a wetland evaluation that the 44
  acre City Parcel did not currently meet wetland
  criteria.

• The Commission merely acknowledges DFGs opinion
  and does not state whether the property meets
  Commission wetland criteria!

7
Wheres the 100-foot setback?

• Coastal Commission July 3, 2001 letter notes the
  potential for wetlands to exist in the County
  portion, and mentions the need for a 100- to
  300-foot setback buffer
• May 21, 2002 LSA wetlands delineation study finds
  potential Commission wetlands in County portion,
  yet no setback is included in the tract map

8
100-foot setbacks on the County parcel
9
Hydric SoilsMay 21 2002 LSA report in EIR

• Documents hydric soils on County portion, but
  speculatively dismisses the findings
• may be remnants from a time prior to
  construction of the Wintersburg Channel
• soils exhibiting hydric indicators were
  deposited on site, and were then intermixed with
  the native soil during past ground disturbance
  activities (i.e. illegal dumping)
• These assertions cannot be proven!
• Ignores the likelihood these hydric soils result
  from current wetlands conditions

10
Hydrophytic Vegetation

• LSA uses the illegal dumping excuse to dismiss
  the presence of hydrophytic vegetation on the
  County portion (cannot be proven!)
• EIR responses to comments dismiss hydrophytic
  vegetation by blaming it on seeds laying dormant
  for years and then suddenly sprouting in
  unusually wet years (DUH!!!)

11
Consecutive Days of Ponding Water

• See Dr. Jan Vandersloots June 14, 1998 comment
  letter in EIR Volume III

12
16 Consecutive Days of Ponding

• December 7, 1997 December 22, 1997

13
December 7, 1997
14
December 9, 1997
15
December 13, 1997
16
December 14, 1997
17
December 15, 1997
18
December 16, 1997
19
December 17, 1997
20
December 18, 1997
21
December 19, 1997
22
December 20, 1997
23
December 21, 1997
24
December 22, 1997
25
45 Consecutive Days of Ponding

• January 12, 1998 February 26, 1998

26
January 12, 1998
27
January 14, 1998
28
January 15, 1998
29
January 16, 1998
30
January 17, 1998
31
January 18, 1998
32
January 19, 1998
33
January 20, 1998
34
January 21, 1998
35
Plus additional omitted photographs taken on the
10 days of January 22-31, 1998
36
February 1, 1998
37
February 4, 1998
38
February 5, 1998
39
February 7, 1998
40
February 8, 1998
41
February 9, 1998
42
February 10, 1998
43
February 12, 1998
44
February 15, 1998
45
February 16, 1998
46
February 19, 1998
47
February 24, 1998
48
February 26, 1998
49
A River Runs Through It

• (and so does illegal dumping of fill)

As documented by 50 years of aerial photography
50
Things to look for

• The ephemeral channel running through the site,
  consistently visible over 30 years (only briefly
  mentioned by EIR)
• Substantial illegal fill dirt being dumped in the
  Smokys Stables area in order to raise land
  elevations
• Correlation to daily rainfall records show
  consecutive days of ponding in many years (and
  not just El Nino years!)
• 8.3ac former EPA-designated wetland
• Additional ponds adjacent to the Wintersburg

51
12/26/52 - EIR
52
3/24/59 EIR ponding 36 days way below avg
season
53
5/1/67 ponding 32 days avg season
54
1/31/70 EIR ponding 22 days way below avg
season
55
6/28/70 - EIR
56
10/26/73 - EIR
57
2/17/75 - EIR
58
12/28/76 - EIR
59
1/24/78 ponding 30 days - way above avg season
60
12/14/78 EIR ponding 31 days above avg
season
61
2/25/80 EIR ponding 29 days above avg
season
62
1/31/81 EIR ponding 4 days below avg season
63
3/15/81 ponding 20 days - way below avg season
64
3/19/82 ponding 22 days avg season(looking
south)
65
2/19/83 EIR ponding 37 days way above avg
seas.
66
4/14/83 way above avg season
67
4/7/84 ponding 2 days way below avg season
68
12/11/85 ponding 26 days avg season(looking
south)
69
3/19/86 EIR ponding 11 days avg season
70
1/9/87 - EIR rain 1/4/87 way below avg season
71
1/21/87 EIR rain 1/4/87 way below avg season
72
2/20/87 ponding 15 days way below avg
season (looking south)
73
July 1987(looking west)
74
1/24/88 EIR - rain 1/17/88 way below avg
season
75
2/11/88 rain 2/2/88 way below avg season
76
1/30/89 EIR rain 1/24/89 way below avg
season
77
10/27/89 rain 10/21/89 way below avg
season(looking southeast)
78
1/27/90 rain 1/13/90 way below avg season
79
3/15/90 - EIR rain 3/12/90 way below avg
season
80
1/14/91 EIR rain 1/3/91 below avg season
81
1/8/92 EIR rain 12/28/91 avg season
82
1/9/92 - rain 12/28/91 avg season
83
1/24/92 EIR rain 1/3/92 avg season
84
3/4/92 ponding 29 days avg season(looking
east)
85
1/3/93 EIR rain 12/28/92 way above avg
season
86
2/10/93 ponding 62 days way above avg
season(looking southwest)
87
5/14/93 EIR rain 3/26/93 way above avg
season
88
1/3/94 EIR rain 12/12/93 below avg season
89
3/14/94 rain 3/6/94 below avg season(looking
southwest)
90
1/28/95 EIR ponding 26 days way above avg
seas.
91
March 1995
92
3/27/95 EIR ponding 22 days way above avg
season
93
3/19/96 ponding 29 days below avg season
94
1/29/97 ponding 33 days avg season(looking
south)
95
2/14/97 rain 2/11/97 avg season
96
3/10/98 ponding 28 days way above avg season
97
Total precipitation (inches) for seasons with 18
or more consecutive days of ponding
Ponding occurs in all types of seasons, not just
El Nino!
98
But Shea had a problem -- too much proof of
ponding!

• Solution Fill in the ponding areas!

99
Farming or illegal grading? You decide!
April 22, 1998 (rain March 26)
100
With not one bulldozer, but two!
April 22, 1998
101
Note the elevation difference between the
bulldozer and the ponding
102
Now you see it -- March 10, 1998
103
Now you dont late 1999 or 2000
104
April 25, 2002
105
But the ponding still persisted
106
March 14, 2001
107
March 18, 2001
108
March 23, 2001
109
The solution to incriminating ponding?

• More farming with bulldozers!

110
March 28, 2001
111
Selective Soil/Water Testing

• Avoided the interesting locations

112
Need Soil Tests in Subsidence Zone
113
Insufficient Testing for PCBs in Soil

• No transformers assumed to mean no PCBs
• There has been no soil testing to date to check
  for PCBs
• This seems grossly irresponsible given the
  proximity to the confirmed PCB dumping ground at
  the end of Graham Street
• CA DTSC has been contacted

114
Water test pit locations March 1997
115
Tidally-influenced groundwater
116
LSA Report Inaccurate Regarding prior converted
croplands

• EIR erroneously states that in 1992 Army Corps
  said that there were no wetlands
• Army Corps really just said that they could not
  exercise jurisdiction
• Prior converted croplands designation is
  irrelevant to the Coastal Commission, which uses
  a different set of definitions

117
Prior Converted Croplands or Farmed Wetlands?

• Prior Converted Cropland inundation less than
  15 consecutive days
• Farmed Wetlands inundation for 15 or more
  consecutive days (subject to CWA Section 404
  regulations) in at least 51 of rain seasons
• Our current photographic database can prove
  Farmed Wetlands status in 44 of seasons since
  1966-1967

118
A New Wetlands Delineation is Overdue for the
City Parcel

• Delineations are only valid for 5 years, and the
  last one is getting old
• 11/23/96 first site visit (nearly 6 years ago)
• 07/11/97 amended final draft (over 5 years ago)
• 11/20/97 last site visit (4 years 11 months ago)
• 12/17/97 Lisa Kegarice delineation letter sent
  (4 years 10 months ago)

119
New Delineation Justified by Sloppy Work and New
Evidence

• Coastal Commission has not said they agree with
  the old delineation
• Sloppy water table testing the first time
• New aerial ponding evidence

120
Kegarice used the WRONG delineation manual in
1997!

• 1987 USACE delineation manual was used
• Hydric soil info was obsoleted in 1992
• 1994 Memorandum of Understanding said that the
  National Food Safety Act Manual (NFSAM) will be
  used for federal delineations of agricultural
  land
• NFSAM updated in 1996 with Field Indicators of
  Hydric Soils
• A new delineation must be performed using NFSAM!

121
Buried Secrets July 13, 2001

• Or, Indiana Jones and the Storm Drain of Doom

122
The map shows the existing 60 storm drain
123
Shea contractors dug several deep holes near the
storm drain
124
Bricks quick-set mortar were installed down in
the holes
125
Public Works denies all knowledge

• HB DPW initially said it is a County drain
• County said it is a City drain
• HB DPW then agreed it is a City drain, but had no
  idea of what work was being done
• HB DPW then surmised that Shea was merely
  confirming the location of the drain
• But later that night, the truth is discovered!

126
Indiana Jones and The Storm Drain of Doom

• A member of the loyal opposition enters the storm
  drain after midnight to explore
• Apparently there are multiple southerly
  extensions (leach lines) of this drain running
  under the Shea property
• The Shea contractors had bricked off these
  extensions in order to prevent water from the
  main drain from flowing under the Shea property

127
The map neglects to mention the leach lines that
are now sealed
Bricked-off leach lines
NOT TO SCALE!
128
What was Shea up to here?

• De-watering a wetland whose status is still
  subject to legitimate debate?
• Performing work on city storm drains without a
  permit?
• Increasing the load on the already overburdened
  Graham storm drain?
• Unethical behavior that should not be implicitly
  sanctioned by the City of HB?

These questions demand further Council
investigation!
129
Wetlands Summary

• Proven ponding tendencies (not just El Nino
  years)
• Repeated, unpermitted actions by Shea to prevent
  future ponding
• Sloppy, improper, no longer valid wetlands
  delineation of the city parcel
• EIR should not be certified without a new
  wetlands delineation for the city parcel

130
Water Quality Issues
131
Hidden Negative Water Quality Impacts

• Parkside adds significant new runoff to the
  Slater Channel
• More frequent Slater pumping will be needed to
  maintain the -6 ft MSL elevation
• Slater pollution will enter the Wintersburg
  Channel more frequently than today
• Resulting in extra days of pollution for Bolsa
  Chica Huntington Harbour

132
Solution Move the New Pumps to the North Bank of
the Wintersburg

• WIN costs less to build
• WIN doesnt send extra Slater pollution to
  Huntington Harbour
• WIN superior safety by not relying on Slater
  Pump Station as a single point of failure
• WIN all maintenance expenses whatsoever could
  be funded via Improvement District

But dont forget that County pump permit!
133
Whats that awful smell???
EIR Volume IIA, Section 5, page 4-1
134
September 20th Coastal Commission letter on water
quality

• fundamentally flawed
• used inaccurate data and assumptions
• there will not be 45 area-wide reductions
• impacts to Huntington Harbourhave not been
  fully considered
• impacts to the Bolsa Chica Reserve have not
  been fully considered

135
Water Pollutant TMDLs are Coming for Huntington
Harbour

• 303(d) pollutant limits will be established in
  the 2006-2010 timeframe, according to the Santa
  Ana RWQCB
• Adding Parkside pollution today will make it
  harder and more expensive to meet these limits
  tomorrow
• HB will be stuck paying the clean-up bill, not
  Shea!

136
Drainage/Hydrology Issues

137
City/County Disagreement on Slater Pump Station
permits

• Bob Righetti and other city staff insists no
  permits are needed for the new Shea pumps
• But the County insists that permits are REQUIRED!
• 05/27/98 County letter DEIR comment
• 09/04/02 County letter to Public Works
• City still denies the permits are required

138
Lack of Cooperation

• City insists the original 1964 Slater Pump
  Station permit covers new Shea pumps
• Though conditions have changed greatly in the
  past 4 decades, no new permit will be sought from
  the County
• The County has ultimate authority over the
  Wintersburg, a key piece of public safety
  infrastructure which doesnt meet modern design
  standards, and should be consulted

139
Evading the Safety Limits?

• County required an automated stilling well
  throttle-back sensor for the Shields Pump Station
  to protect the Wintersburg
• No County permit and no such sensor is planned
  for the Slater Pump Station
• The Slater Pump Station should be held to the
  same modern safety standards as the Shields Pump
  Station!

140
Increased Flood ThreatAnother Deficient EIR
Analysis

• Parkside adds to runoff in Slater Channel, so the
  pump station will be expanded
• but the County may require throttle-back limits
  to protect the Wintersburg Channel from
  overflowing
• Therefore if the Wintersburg is full, the new
  Slater pumps may not operate, thus increasing the
  risk of a Slater Channel flood which is not
  analyzed by the EIR

141
A Questionable FEMA CLOMR
If the pumps are not operated at full capacity,
the changes to the flood hazard information
described in the CLOMR may not be accurate. In a
separate letter, to Orange County Officials, we
are expressing concern over this issue.
-- FEMA letter dated July 29, 2002
The much-hyped floodplain reductions may not be
realized!
142
Dont be fooled!
143
Shifting the Flood Risk

• Parkside runoff north of the Wintersburg will be
  sent south to the Slater Channel
• Existing Slater neighborhoods will be at risk
  during El Nino-class storms at Wintersburg high
  tide
• Shifting the risk burden to other neighborhoods
  is bad public policy, and so are single point of
  failure designs!

144
EIR Deficiency Does Not Analyze Any Drainage
Alternatives

• No discussion of the MUCH simpler solution of
  building a new pump station at Lot O and directly
  connecting to the Wintersburg Channel
• All costs whatsoever could be funded by an
  Improvement District

145
EIR Deficiency Does Not Analyze Impact to Local
Aquifers

• Seawater intrusion already a problem
• Paving this property will greatly reduce aquifer
  recharge from fresh rainwater
• Seawater intrusion will then worsen
• Orange County aquifers currently significantly
  overdrawn due to drought and population increase

146
EIR Deficiency No Analysis of Impacts of
Drainage Failures On Kenilworth Tract

• Parkside will sit at significantly higher
  elevation than adjacent Kenilworth tract
• If there is failure of any component of the
  Parkside drainage system (i.e. clogged drains,
  etc), flood conditions will compound for the
  Kenilworth homes and surroundings
• EIR does not analyze or mitigate for these
  failure conditions

147
Subsidence Issues
148
Kenilworth Subsidence Zone
149
Patios are cracking
150
Walls are splitting
151
Walls are tilting
152
Walls are sinking
153
by as much as 12 inches!
154
Insufficient Protections During Overexcavation
Dewatering

• Shea insists these techniques are time-tested and
  wont harm adjacent homes
• HB has history of residential subsidence problems
• Shea promises careful monitoring, but the first
  signs of trouble may be cracked foundations on
  Kenilworth homes
• Shea and/or HB will be held liable for any
  problems during construction or thereafter
• If theyre so certain of their mitigation
  measures they should provide indemnification for
  any and all casualty loss to existing homeowners

155
Liquefaction Issues
156
Liquefaction New Threat Caused by Mitigation in
Final EIR

• Liquefaction can occur on any wet, uncompacted
  sub-strata during a temblor
• Parkside plans propose a 50-wide Paseo Park to
  mitigate vibration and likely subsidence problems
• sloped toward 22 existing homes on Kenilworth
• they claim that neither dewatering nor remedial
  grading will be required
• made of tens of thousands of cubic yards of fill

157
Liquefaction New Threat Caused by Mitigation in
Final EIR

• The wet, uncompacted sub-strata together with the
  new fill would be subject to liquefaction,
  therefore the whole slope would be at extreme
  risk for liquefaction and slumping during a
  temblor, endangering homes on Kenilworth
• The Final EIR doesnt account for this newly
  created and foreseeable problem which is a likely
  consequence of their proposed mitigation

158
Traffic Issues
159
We Demand a Traffic Study Recount!

• Data collected during Labor Day week when many
  people are away on summer vacations (and not
  driving on HB roads!)
• OVSD gym EIR says collecting traffic data during
  typical weekday peak commute hours is best
  (this EIR was the result of a successful court
  challenge)
• Holiday weeks are not typical!
• OVSD enrollment was still ramping up

160
OVSD Enrollment Still Ramping Up

• Some families still on vacation
• Clueless parents slow to realize school has
  resumed
• Incoming transfers from year-round districts with
  different academic calendars
• First enrollment statistics not collected until
  September 27th

Source Sharon Tugwell, OVSD Financial Services
161
1997Project HCM p.28Southbound Graham at
Glenstone
162
2002Project HCM p.36Southbound Graham at
Glenstone
Would an accurate count show unacceptable LOS E?
163
Restriping a Fraudulent Mitigation

• The EIR proposes left-turn median striping to
  mitigate Graham congestion
• But drivers are already using a de-facto
  left-turn median of their own creation
• So painting some extra lines in the middle of
  Graham wont change anything!
• How about conditioning for a traffic signal at
  Graham Glenstone instead?

164
Restriping still a bogus mitigation!2002Project
Improv HCM p.40
Traffic study shows a mythical 55 delay
reduction after restriping
165
Increased Traffic Congestion

• Graham Street already congested at peak periods
• Congestion will be worsened by
• Marine View gym (in progress)
• Parkside (proposed)
• Hearthside/Fieldstone (proposed)
• Circulation Alternative B (exit to Bolsa Chica
  St) needed to reduce the additional burden on
  Graham Street!

166
Pressure to open Greenleaf to through traffic

• Connection to Greenleaf proposed as emergency
  only access
• But a future City Council could open it up to
  through traffic, despite 100 Greenleaf
  opposition
• Circulation Alternative B (Bolsa Chica St) would
  remove the Greenleaf temptation and provide
  suitable emergency access

167
Graham Haul Route Needs Reanalysis

• September 9th 2002 traffic study shows
  significantly more traffic on Graham
• EIR conclusions about haul route impacts are
  based on stale 1996 traffic data
• These impacts of moving up to 285,000 cubic yards
  of fill need to be reanalyzed

168
Graham Glenstone Peak TrafficThursday,
February 14, 2002, 735AM
169
Glenstone U-turnsFriday, September 6, 2002
733AM
170
Left Turn Trouble at Kenilworth

• Backups caused by the Parkside signal will create
  left turn delays when exiting Kenilworth onto
  northbound Graham
• Southbound cars waiting at the signal will cause
  dangerous visibility problems
• Keep Intersection Clear striping wont solve
  the visibility problem

171
North Graham from KenilworthMonday, September 9,
2002 731AM
172
South Graham from KenilworthMonday, September 9,
2002 731AM
173
Fire/Medical Response Issues
174
Planning Commission DecisionCertify the
Parkside EIRBased Upon CEQA Compliance

• Analyzes the potential environmental impacts
• Identifies project alternatives
• Identifies mitigation measures to lessen the
  projects impacts

175
Analyzes the potential environmental impacts
(EIR Errata)

• Future development of the project site may
  create a need for additional fire protection
  services. The increase in the number of
  residential units and the number of individuals
  brought into the area, as well as the resulting
  increase in traffic will directly affect the fire
  department's responses.
• Additional impacts to current response times are
  anticipated with relocation of the Heil fire
  station. Response time from the new location to
  the project site would be greater than 5
  minutes.
• Implementation of Mitigation Measure 1 will
  reduce impacts related to the need for adequate
  response times and additional fire protection
  services to a level less than significant.

176
Edwards Response Time Estimates
600 - Greenleaf
515 - Glenstone
430 - Grhm/Slater
600 - Bates
?
545 - Candle
?
?
?
545 - Felson
?
Hearthside/Fieldstone
?
?
?
?
?
177
Identifies project alternatives

• No project/no development
• Development under existing zoning
• Alternative location
• Alternative park site location
• Alternative roadway connections
• Reduced density alternatives (4)
• Development incorporating the existing General
  Plan fire station designation is NOT included in
  EIR!

178
Keep the General PlanFire Station Designation!

• HB General Plan clearly shows the Graham/Slater
  area to be emergency response deficient.
• Recent H.B.F.D. tests have not proved otherwise
  so much for exceptional degree of overlapping
  coverage from Warner, Edwards, and Relocated
  Heil stations.
• G.P. Policy P.F. 2.1.1 Locate fire stations in a
  manner which will enable fire response times to
  meet a five minute standard, 80 of the time.
• Graham/Slater residents are just as entitled to
  prompt emergency service as other residents!

179
Types of Calls to H.B.F.D.(by percentage)
180
Parkside EIR fails on All 3 Counts

• It does NOT adequately analyze the potential
  Public Services environmental impacts to
  surrounding homes.
• It does NOT identify a project alternative
  incorporating a fire station.
• It does NOT identify mitigation measures to
  lessen the projects Response Time impacts to
  surrounding homes, nor does it identify any
  medical safety mitigations.

181
Aesthetics/Light and Glare Issues
182
Headlight Mitigation Too Slow

• Car headlights on project streets will shine into
  Kenilworth homes
• Paseo Park will be landscaped to block this light
• But these trees wont be planted until
  construction is completed in 4 years
• The trees wont reach mature headlight-blocking
  heights for another 5 years

183
Noise Issues
184
Graham Street Haul Route Impact Needs Reevaluation

• September 9th traffic study shows substantially
  more existing traffic (and thus noise) on Graham
• If the adjacent Bolsa Chica mesa cannot be used
  for the fill borrow site, Graham will be used as
  the haul route
• EIR needs to reevaluate Graham haul route noise
  impacts in light of higher traffic levels

185
Construction Schedule Will Impact Retirees and
Telecommuters

• City construction schedule is Monday Saturday,
  7AM 8PM
• Impacts to retirees, telecommuters, and swing
  shift workers, stay-at-home moms, children and
  care-givers are not discussed
• The proposed mitigation measures will not reduce
  the impacts for these classes of residents

186
Aircraft Noise Impacts Omitted

• Neighborhood is under the Long Beach / Los
  Alamitos landing flight paths
• Military and commercial aircraft fly low enough
  to read tail logos
• Beach banner aircraft also present during summer
  months
• EIR does not factor any of this aircraft noise
  into its CNEL impact calculations

187
On Final Approach to Long Beach
188
Suggested Conditions of Approval to Reduce the
Negative Impacts
189
Suggested Conditions of ApprovalTraffic

• Require a secondary entrance/exit
• Require signalization of Graham Glenstone
• Forbid the use of stop signs on B street to
  reduce noise impacts to adjacent Kenilworth homes
• Hold Shea to their repeated promises to convey
  property rights to Kenilworth / Greenleaf
  homeowners to give them control of access,
  preventing opening of Greenleaf Lane to through
  traffic.

190
Suggested Conditions of ApprovalDrainage/Hydrolog
y Conditions

• Seeking a County permit for new storm pumps must
  be REQUIRED (the current phrase necessary
  permits leaves too much wiggle room)
• Install the new pumps at Lot O for direct connect
  to the Wintersburg Channel, with all costs
  whatsoever funded by an Improvement District

191
Process Issues
192
Accuracy Counts!

• Invalid maps at study sessions
• Missing sections from Final EIR
• Contradictory statements remain in Final EIR
• Egregious typos (4 miles to Marine View)
• Half-baked fire response testing
• Stale, fantasy traffic data
• Botched staff report distribution
• Staff in denial regarding County permit
  requirements for Slater Pump Station

193
But wait, theres more

• Frequent release of significant new information
  as Late Communications
• Bob Righetti of HB DPW refusing to return e-mails
  and voice mails
• Dean Albrights traffic maps withheld from agenda
  packet by Scott Hess

194
Conclusions
195
Its Simply a Bad Project with a Bad EIR!

• Its a fundamentally unbuildable wetland
• Too many negative impacts on existing
  neighborhoods Existing homeowners need better
  protection and indemnification against
  damage/loss
• Too many omitted impacts and non-mitigations in
  the contradictory, error-laden, deficient Final
  EIR
• Fails to fulfill 7 of 10 City Goals stated in
  1996 GP

Please vote to deny certification of the EIR!