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CVP asks Marin County to adhere to CEQA on Sir Francis Drake Rehab Project FEIR

Community Venture Partners, Inc. has submitted the following comment letter to the Marin County Public Works Department, with attachments, regarding the inadequacies of the County's Final Environmental Impact Report and Appendices of Responses for the Sir Francis Drake Rehabilitation Project.


Dear Mr. Dawson:

Attached please find comment letters by Edward Yates, our legal counsel, and by air quality expert Geoffrey Hornek, regarding the Final Environmental Impact Report for the Sir Francis Drake Boulevard Rehabilitation Project. Letters previously submitted by Mr. Yates, Geoffrey Hornek, and traffic consultant, Robert Harrison, in December of 2017, are hereby incorporated by reference.

We find the county’s FEIR responses to each of these comment letters evasive, non-responsive and / or otherwise failing to address the key legal issues raised, and instead simply restating the EIR’s incorrect assertions and assumptions.

For example, as we have repeatedly noted, the project information provided about lane narrowing is not specific to each lane on each section of the street. The county’s responses are circular and refer to the Parisi’s study which notes that lanes will be 11' and 12'. However, we don't know where that actually occurs. This is important because many lanes are now 15' wide.

More importantly, there is no analysis that includes the new narrowed lanes. As noted by our traffic expert, Robert Harrison, the only analysis Parisi did was of the existing traffic on the existing street configuration and lane widths.

The county’s attempt to conceal this is dishonest and in violation of the fundamental requirements of the California Environmental Quality Act (CEQA): its obligation to provide the public with specific project information and adequate analysis of a proposed design, and provide adequate time for public comment, prior to the agency making its decision on a proposal.

Community Venture Partners, Inc. has done its best to alert the Marin County Public Works Department that their DEIR and now their FEIR are inadequate in addressing the agency’s responsibilities to the public and the requirements for analysis of potentially significant impacts, under CEQA. We have done this diligently and in a timely manner in the hopes that the County would undertake such analysis and disclosures of information, as required.

Unfortunately, as we have experienced in every other instance in dealing with Marin County agencies in the past four years, our respectful requests and the evidence we have produced on behalf of the public’s interest, has been summarily ignored or refuted without any supporting evidence, analysis or citation of legal authorities.

In all previous instances, the courts have supported our clear and simple arguments that the county’s actions are in violation of state law, which has resulted in considerable costs to Marin taxpayers.

It is with the sincere intention of avoiding this outcome and in the hope that the County will act responsibly this time, that we are submitting these comments, today.

Sincerely, Robert Silvestri

President, Community Venture Partners, Inc.