The proposed project is clearly inconsistent with several County general plan policies.

The activities allowed in the Private Conservation Areas are not clear and therefore the impacts from those activities are largely excluded from the EIR.

Many aspects of the project are unclear and not defined in the EIR or properly analyzed. For example, the Architectural and Landscaping Guidelines are not binding, are only applicable to "single family lots", and are "advisory".

No neutral economic analysis of alternatives has been commissioned. Lacking this, the public cannot understand and comment on the issue of what level of development is feasible.

The County Park Development should be more "natural", fewer structures and with informal parking areas.

The EIR does not properly analyze the impact of the proposed development on the "designated remainder parcel" (the 200 acre gift). In other words, what of value is left after the construction of the mansions.

The management of and access to the "Private Conservation Area" and "Designated Remainder" are not clear.

The dEIR Project Objectives are too narrow and restrict the range of alternatives considered by the County.

The DEIR does not adequately describe the project site's significant visual resources as required under the County of Santa Barbara Environmental Thresholds and Guidelines Manual.

The DEIR does not accurately classify aesthetic impacts on the eastern portion of the SMF.

The visual simulations rely on screening vegetation that would be disallowed by fire safety requirements and would require 20-25 years to reach mature stature and provide the degree of screening shown.

Visual simulations must be provided and short-term aesthetic impacts assessed based on expected views of the development that conform to fire safety requirements.

The mitigation measures proposed in the DEIR lack the level of detail and specificity required to reduce significant impacts to the maximum extent feasible.

Groundwater may be affected from proposed septic tanks and on-site retention basins.

There are slope stability issues in the Sespe formation along the proposed park access road in the western development area;

Slope stability issues are associated with the Rincon formation in the eastern project area.

The impacts from erosion and sedimentation during construction activities are significant.

The Draft EIR indicates there are potential landslide/slope stability issues associated with undocumented fill.

There is an inadequate cumulative analysis of potential sedimentation impacts in the Draft EIR.

Geological issues present both public health and safety issues, and these are not discussed sufficiently in the EIR.

An earthquake fault crosses two proposed development envelopes .

The important Cachuma aqueduct cuts across the southern portion of SMF.

Rincon formation with unstable soil with ancient and recent landslides is found on both the eastern and western boundaries.

Radon-producing Rincon shale is found over virtually the whole area of the SMF.

The project's Cumulative Effects include collective losses to several animal populations on site.

The dEIR fails to provide an adequate baseline of invertebrate species.

Outdated Native Plant Society plant and California Department of Fish & Game's Special Animals lists were used to identify sensitive plants and animals.

Since the EIR preparers focused only on native grass species, the percent cover of native grassland species may be significantly different than for just native grass species. This could mean that the amount and location of native grassland present onsite was underestimated.

Field surveys for vegetation sampling were conducted when many species are dormant (during the summer and fall months). Inaccurate delineations of native and nonnative grassland habitats may be presented in the DEIR from a lack of adequate sampling and consideration of the winter and spring native annual flora.

The County's definition of native grassland was not used in the DEIR. If this threshold is used, it may result in significantly more area of native grassland onsite than stated in the DEIR.

The dEIR does not include mapping and impact analysis, and County Policy consistency, of many native perennial grass species.

Impacts to annual grasslands, even those dominated by nonnative grasses, should be considered significant and contributing to the direct and cumulative losses of grasslands regionally and statewide.

Off-site mitigation does not compensate for impacts (loss and degradation) of native grasslands on site.

The DEIR fails to address impacts to rare lichen species other than indirectly through concerns about impacts to the grasslands in which the lichen boulder field occurs.

Mitigation for direct impacts to all sensitive plant species is not specific enough, infeasible, and too general to be adequate. It relies primarily on future study with no specifics on how direct impacts to each sensitive plant species is mitigated to a less-than-significant level, which does not satisfy CEQA requirements.

Development of lots 12-15 would result in a significant loss of White-tailed Kite nesting and foraging territory.

The project will probably reduce the numbers of certain species such as the Rufous-crowned Sparrow, Blue-Gray Gnat Catcher, Lazuli Bunting, Badger, Ring-tailed Cat, some bat species, and others.

The project would fragment and devalue habitat from the removal of vegetation for safety from wildland fires.

The EIR notes that there is insufficient water supply/pressure from GWD to meet fire codes. Mitigation measures may not provide an adequate level of safety to permit residents to shelter in place.

The effect on the remainder parcel of increased fire hazard on the developed portion should be analyzed.

The EIR does not address compatibility of the proposed landscape plans with fire safety requirements.

Wetlands at the site are undervalued or underrepresented in the dEIR.

Only "jurisdictional wetlands," are discussed in the EIR, that is, federal wetlands. The wetlands mapping is therefore incomplete.

We may lose the association of wetlands with other habitats and the biocomplexity that association supports.

The project may affect groundwater absorption and recharge, and a disruption to the surface and groundwater flow regime may result in erosion and accelerated sediment release.

There could be groundwater impacts from proposed septic tanks and on-site retention basins.

Surface water impacts could result from increased storm water runoff associated with impervious surfaces.

How does water and sewage management on the developed portion affect the remainder parcel and the downhill parcels, including the proposed county park?

The Draft EIR provides an inadequate assessment of potential septic tank impacts and alternatives (connection to the Goleta Sanitary District).

The Draft EIR does not adequately assess potential impacts from on-site storm water retention.

Impacts to existing recreation would occur since recreational uses of the area would likely be prohibited outside of the proposed public park area.

There were major concerns stated by several commenters regarding the application and interpretation of Government Code 65589.5. Many commenters wondered whether CEQA impacts will be allowed if this code is used to require the County to not condition or deny development on San Marcos Foothills.

The projected "benefits" of the affordable housing component should not outweigh the significant policy changes, policy inconsistencies, and precedent-setting nature of the proposed General Plan Amendments.

Police services for the proposed park may be higher than estimated.

The EIR fails to include a discussion of roadway impacts for State Highways 154 and 192.

No grading plan has been presented in the EIR, so it is impossible to assess air quality impacts under the proposed development scenario.

Removing the cattle will result in damaging effects and the parcels remaining undeveloped will be too small for grazing.

Eliminating grazing from the project site without a careful management and restoration plan may result in further degradation of the existing native grasslands onsite.

The agricultural land conversion impacts discussion does not present an adequate degree of analysis and fails to present evidence to support the conclusion reached.

Mowing to Replace Cattle should be analyzed.

The effects of the removal of cattle on the Designated Remainder (DR) will likely significantly alter its character, functionality, and value.

The project does not conform to the zone district intent of clustering to maximize the preservation of open space.

The project does not conform to the open space requirements of Article III.

The dEIR should indicate clearly how many functional dwelling units really are proposed. Guest houses, pool houses, carriage houses, big garages, fifth bedrooms with separate entrances, barns, etc. all have the potential to be de facto separate residences.

No study has been undertaken to show if the disturbance of known archaeological resources found on the property can be avoided.

Mitigation measures to address solid waste issues for the proposed project are inadequate and generally infeasible.

Reducing the acreage of the proposed park would likely reduce the amount of solid waste generated by the project.

The DEIR does not analyze the cumulative impacts of all related projects.

The cumulative impacts of the proposed project would be significant.

Mitigation measures proposed are too standard and unspecific to truly address impacts.

The alternatives have not been analyzed in any serious way. Clustering the houses to the southern and central portions of the site would avoid significant impacts to the views and the biology.

The EIR should include neutral professional economic analysis of the economic feasibility of the alternatives studied.

The suite of alternatives leaves out an obvious option for no housing at the high elevation at the western part of the site.

Avoidance of the ecologically sensitive, visually stunning, and geologically unique West Mesa is a feasible alternative.