Mitigations do not lead to predictable reduction of impacts.

A number of the measures that the EIR proposes to mitigate significant impacts are too vague to qualify as mitigations under CEQA because they rely on future studies that are not required to meet a specified performance standard. Examples of the problem include:

• Mitigation HAZ-6 appears to call on the City to set standards of "acceptable health risk" in setting building requirements for uses constructed on the benzene plume.

• Mitigation T/C-2 to reduce traffic safety impacts of a school located at a busy intersection that calls for site planners to "pay close attention" to the issues.

• Mitigation AQ-1a and 1b requires the developer to take specified preventive actions but does not assign responsibility for enforcement to a public agency (as, for example, by incorporating the requirements into the Master Plan, development plan, or building permits).

• Mitigation AQ-2 to reduce regional air pollution emissions presents a menu of options with no requirement to adopt any of them and without setting a performance standard for the mitigation to achieve.

• Mitigation PUB-2a and -2b require a plan to be prepared to reduce the impact of demolition debris on landfills but set no performance standard for the plan to achieve.

• Mitigation UTL-5 calls for gas line abandonment plan that is to be prepared by an unknown party ("the Project or other responsible entity") to be approved by an unknown entity.

• Mitigation AES-3 calls for a final design plan for a sound wall and landscape plan that sets a vague standard (no adverse effect on the visual character of the Atlantic Avenue frontage).

Additional Information Required: Set performance standards and procedures that ensure that a predictable lessening of impacts will occur.

Many of the plans called for by the EIR do not have to be approved until the Project has received all of its entitlements, rather than at the earliest possible stage of project planning.

Preparing mitigation plans after approval of the Master Plan, and in many instances, until after approval of the Development Plan, forecloses opportunities for Project-wide mitigations that could be more effective for a project of such a large scale. Opportunities to integrate the mitigations into the design of the Project are, in general, forfeited if the various plans are to be approved after all design decisions have been made. Examples of unnecessary deferral of mitigation plans include the following:

MITIGATION	PURPOSE	DEADLINE	FORFEITED OPPORTUNITIES
HAZ-6	Measures to avoid exposure to subsurface soil gases	Apparently at building permit state	To locate buildings elsewhere on Project site where soil gases are not a problem
T/C-1	Traffic Control Plan	Required prior to issue of building or grading permits	To phase project to minimize problem
T/C-2	Site plan that addresses safety issues	Review at granting of encroachment permit	To locate buildings elsewhere on Project site where safety is not an issue
T/C-19a	TSM Plan	Adoption prior to occupancy	To cluster development to make transit service more efficient
AQ-2	Measures to reduce air pollution	No deadline set	To cluster development to make transit service more efficient
PUB-2a and b	Plan to manage construction debris	No deadline set	To phase project to maximize deconstruction opportunities

Correction Required: Provide for mitigation plans to be developed at the earliest possible moment.