Fountaingrove Environmental Impact Report - City of Santa Rosa ...

ES082008001BAO_Fountaingrove_publicComments_v3.indd_090408_lho
MARGASON – 7
MARGASON – 8
MARGASON – 9
MARGASON – 10
Written Comments on Draft Environmental Impact report for the Lodge Project,
page 3-92 but the extent of such soils is not yet defined hence the impact of such grading has not
and cannot be addressed in the DEIR. This is unacceptable because the final extent of disturbance
to the site topography hence environmental impact has not yet been determined. The EIR cannot
defer the evaluation of such impacts until the design phase; they must be determined now by
further on-site soils studies before a final EIR is completed.
Section 3.6, pages 3-67 to 3-93, addresses geology and faulting and this section is one of the
more extensive and responsive parts of the DEIR. Our 2A-1 thru 17 scoping comments in volume
II apply as follows. Scope comments 2A1 thru 4 are addressed by the DEIR and according to
Giblin and Associates no active fault was found by them on the lodge site, the nearest active trace
of the Rogers Creek fault being across the street of TLH in the visible sag pond about 70 feet to
the west. Bedrock faults were found on the site but Giblin dated them as pre-holocene hence they
were rated as inactive. One would hope that no active faults were missed in non-trenched areas
and Giblin should have to certify as to this in the final EIR..
Page Three
The DEIR does not appear to contain a map showing the locations of the Giblin fault trenches;
this map is missing from his December 7, 2007 study, appendix K of vol. II, which curiously lists
two plate 2’s. This seems to be an error and should be corrected in the EIR.
Scope item 2A-5 was addressed as to very strong shaking from nearby 7+ magnitude
earthquakes. The DEIR states that such hazards are significant and require mitigation. Mitigation
impact 3.6-2 includes site-specific seismic analyses during design but does not specify if such
analyses will include such details as response spectra, computer simulations and finite-element
modeling all of which are needed in this near-fault setting. The EIR is not clear that its
recommended mitigation of “site-specific seismic analyses in project design” goes well beyond
normal building code seismic design. The EIR must indicate that code design alone is not
sufficient for public safety at this site which is in the State of California’s designated Alquist-
Priolo active fault zone. CEQA law does not allow this consideration to be deferred but must be
included in the EIR.
Site and soil stability during earthquakes has not been evaluated in the DEIR but instead is
deferred to the design phase; also the seismic stability of the City-owned earth dams impounding
Fountaingrove Lake has not been evaluated. Scoping items 2A6 thru 11 asked that these items be
addressed in the DEIR but they are not. It is not clear that scoping items 2A14 and 15 were
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