This is Part 3 of our 3-part series on the Well #8 Neighbors Group filing describing 39 deficiencies in City’s Initial Study and draft Mitigated Negative Declaration for the Well #8 permit application. A permit may not be granted until the disclosure defects are remedied. Part 1 is here. Part 2 is here. The entire 21-page document includes text and graphics supporting the comments.
VIBRATION IMPACTS
Comment #29. The MND/IS is deficient because it does not consider the potential vibration impacts on two swimming pools and a water feature that are closer to the Project site than any building.
SOILS IMPACTS
Comment #30. The MND/IS is deficient because it does not consider the potential environmental impacts on soils of the drilling fluid spills and cuttings.
AIR QUALITY IMPACTS
Comment #31. The MND/IS is deficient because it does not consider sodium hypochlorite vapors that will be vented outside when the storage tank is filled and during daily temperature changes.
Comment #32. The cuttings from a drilling operation often emit obnoxious odors, which must be assessed as a potential air quality impact.
AESTHETIC IMPACTS
Comment #33. It is hard to determine exactly what structure is being proposed for the well building and the landscaping. However, neither structure fits in with the high- end homes that surround the site. This particularly impacts the expensive custom homes being constructed across Crestview Avenue from the Project that overlook down on the site.
BIOLOGICAL IMPACTS
Comment #34. The MND/IS is deficient because it does not assess potential direct impacts on biota in the barranca.
Comment #35. Without a professional assessment of “native habitats” and other environmentally sensitive conditions in the barranca, the potential for significant environment impacts on biological resources cannot be evaluated.
LACK OF PUBLIC PARTICIPATION
Comment #36. The MND/IS is so incomplete and contaminated with misinformation that it fails to give the public fair notice and opportunity to participate in the CEQA process.
Comment #37. The MND/IS is deficient because it fails to consider credible environmentally-relevant information that has been in the CUP-403 application file before the MND/IS process was initiated.
Comment #38. None of the proposed “mitigations” has been incorporated into the Project or “committed” to by Crestview.
Comment #39. Crestview has, for three years, refused meaningful dialog with the Well #8 Neighbors Group.
CONCLUSION
The MND/IS is seriously deficient for all the reasons discussed above. It fails to identify all the potentially significant environmental impacts and fails to propose effective mitigations for the impacts that are identified. Crestview should be required to revise and supplement the Application with corrections, additional credible facts, and analyses. Then the City should re-do the Initial Study and the draft Mitigated Negative Declaration (if an MND is still appropriate based on the revised Initial Study) and publish both for public comment.
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