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r- <br />0 0 <br />Mr. Steve Worrall <br />January 13, 2012 <br />Page 7 <br />with the court in the San Franciscans case that inadequate <br />parking is a social impact that may, depending on the project <br />and its setting, result in secondary effects. Consistent with <br />existing CEQA Guidelines section 15131(a), deletion of the <br />parking adequacy question from Appendix G checklist will <br />ensure that the focus of the analysis shall be on the physical <br />changes. Specifically, the Appendix G checklist contains <br />questions asking about possible project impacts to air quality <br />and traffic." (Exhibit 5 [Exccrpt from the Final Statement].) <br />The RFEIR does not show any evidence of the potential loss of a few parking <br />spaces on air quality or traffic. Thus, the alternatives matrix in Table 5 -1 must be <br />adjusted accordingly and will show that on this basis alone Alternative Sites 3, 5, 6 and 8 <br />are environmentally superior to the Project and Alternative Sites 15, 18 and 19 are the <br />environmental equivalent of the Project. <br />C. The Analysis Of Individual Alternative Sites Is Lezally Inadequate. <br />1. Alternative Site 2. <br />In our prior objection letter of October 31, 2011, we provided substantial evidence <br />to show a correct analysis of Alternative Site 2, the Segerstrom Triangle, which actually <br />shows less traffic impacts, less water quality/hydrology impacts, and a likely shorter <br />construction period. The RDEIR also overstates odor and recreational impacts. <br />Further analysis by Mr. Dickson confirms each of these conclusions. In particular, <br />his report notes a likely shorter construction schedule, which will result in a <br />corresponding reduction in air quality emissions. He also quantifies the reduction in <br />traffic impacts. <br />With respect to recreation, in claiming the loss of 0.03 acres of passive <br />recreational space in the Segerstrom Triangle will cause a significant and unavoidable <br />City -wide impact to recreation, the RFEIR asserts that park users will be effectively <br />concentrated in a smaller area, leading to an accelerated physical deterioration of existing <br />park facilities. The response, though, fails to disclose the required analytic route traveled <br />to reach that conclusion. See Laurel Hei htg s Improvement Assn. v. Regents of the Univ. <br />of California (1988) 47 CaI.3d 376. <br />55A -140 <br />