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This lack of professional review has led to misconceptions and the omission of critical information. When a bridge is engineered, the highest water levels are used to guide its design. So it is with buildings and the ground that support them. The hi hest historical groundwater levels are used to calculate liquefaction risk and guide recommended mitigation. The facts in support of findings for Section 9.6.1.3 mistakenly cite a collection of past low groundwater depths as evidence of lack of seismic risk, missing the only figure of importance in calculating liquefaction risk - the historically highest ground water level of 30 -40 feet for this site (Plate 1.2 Historically Highest Ground Water Contours and Borehole Log Data Locations, Orange 7.5 minute Quadrangle, California). Most concerning is the omission of the mitigation recommended by the Geosoils 2017 report. The Results section of the Liquefaction Analysis (Geosoils 2017, Appendix B Liquefaction and Settlement Analysis, page 4) states: "...the potential for liquefaction on the proposed tract poses a low risk to site development, assuming the conclusions and recommendations provided are incorporated into the fmal design and construction of the project." The low risk assigned is dependent, it assumes the recommended mitigation is being followed. Recommendations (Geosoils 2017) Removals "The subsurface exploration revealed that the existing fill and upper five feet of the alluvium are unsuitable for structural support. This unsuitable fill and alluvium should be removed to competent native alluvium in the areas of proposed development and replaced as compacted fill. Removals should be excavated down a minimum of five feet below proposed grades and extend a minimum of five feet laterally..." (Geosoils 2017,page 11) Deepened Foundation Recommendations "it is anticipated deepened foundations will be utilized for the parking structure... driven piles are not recommended due to the gravelly/ rocky layer encountered at the depth of 40 feet." (Geosoils 2017, page 11) Review and Inspection "All foundation and bottom excavations shall be observed by an engineering geologist or a geotechnical engineer prior to the placement of any steel to verify that the proper foundation material has been encountered... Department of Building and Safety Inspector should also observe the excavation. The final result of the lack of a formal engineering review by professionals with specific expertise in relevant areas is that: The EIR is missing an entire section - Geology and Soils. The Facts in Support of Finding for sections 9.6.1.3 "Exposure to Potential Risk of Loss, Injury, or Death - Seismic -Related Ground Failure, Including Liquefaction" and 9.6.3 "Soil Stability" contain substantial errors and omissions. The Finding for both 9.6.1.3 and 9.6.3 is erroneous. It should read: Finding: Less than significant impact with mitigation. The mitigation summary chart should be modified to include the mitigation recommended in Geosoils 2017.