January 4, 2011
City of Encinitas
Planning and Building Department
505 South Vulcan Avenue
Encinitas, CA 92024
Subject: Draft Mitigated Negative Declaration –Desert Rose Subdivision
I have reviewed the Draft Mitigated Negative Declaration (Case No. 09-200 TMDB/DR), the Environmental Initial Study, and Initial Study and Environmental Checklist that are now available for public review.
The Draft Mitigated Negative Declaration should not be approved at this time.
My analysis indicates that a number of conclusions contained in the Declaration and supporting documents are not supported by the data and logic presented in these documents. There are a number of items in these documents that require additional data and/or explanation. In addition, there are omissions relating to corrective policies and a there is no discussion about the impact of the emissions aspect of the construction process.
My comments are attached.
Mark H. Bramson
cc: Scott Vurbeff