March 28, 2018 <br />Ms. Virginia Gustafson-Lucker <br />Page 2 <br />Suitability of Lots 18&19 (formerly Lots 19&20) and Lots 16 & 17 <br />EC 9.8320 (6) requires that the applicant demonstrates at the Tentative PUD phase that the <br />development will not be a risk to public health and safety. Mr. Derrick indicates that his report states <br />that site specific foundation investigation “is recommended for these and all the lots on the east side <br />of the proposed development”. <br />This recommendation does not satisfy EC 9.8320 (6) as the <br /> The PUD, including lot, infrastructure, <br />outcome of such an investigation is not currently known. <br />and storm water system were all designed in the absence of concrete knowledge of the geotechnical <br />and slope stabilityconstraints. <br />In this context it is telling that the “conservation zone” between <br />Lots 17 and 18, which, according to Ms. Schirmer’s testimony was placed there to address the <br />slide mapped by the applicant’s Engineering Geologist, did not cover the actual location of the <br /> <br />mapped slide scarps within Lot 16. <br />Therefore, unless further investigation is conducted to define the landslide parameters, such <br />as depth, configuration, and characteristics of the failure surfaces, and mechanism of the slides <br />none of the lots along the east boundary of the proposed PUD can be considered protective of <br />public health and safety, both for PUD proper, and the areas downslope. <br />Slope Instability <br />Mr. Derrick admits that “there are areas of gross land instability on the east side” and says that they <br />were “mapped to best of \[their\] ability”. As already mentioned during my testimony on March 7, <br />current Standards of Care would require that such mapping include a review of the geomorphology <br />using LiDAR maps. This was not performed. <br />Mr. Derrick furtherstates that my “interpretation of the LiDAR is simply that, an interpretation with <br />no ground reconnaissance of the site...”. This was incorrect when written, as <br />my original testimony <br />included several photos I took on the site, showing trees which showdeformation typically <br /> <br />associated with sliding slope movements and not soil creep!Moreover, my Addendum of <br />march 22, 2018 presents further field evidence of displacements of Floral Hill Drive in the area <br /> The deformations of the road are completely consistent with eastward <br />just downslope of the site. <br />movement of several landslide lobes mapped on the LiDAR. <br />Sandstone vs. Volcanic Rock <br />Mr. Derrick admits that “our test pits predominatelyencountered sandstone”, but goes on to indicate <br />that the northeastern portion of the site is mapped as intrusive volcanic rock on DOGAMI maps. <br />The question begs whether DOGAMI mapping is more important than the material and <br /> Moreover, it needs to be pointed out that DOGAMI’s <br />structure actually present at the site. <br />geologic mapping was never conducted with the advantage of having test pits and, therefore, needs <br />to be treated as “preliminary”, especially at the scale of individual lots. <br /> <br />