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Dale Helvig <br /> <br /> <br />EIR AREAS OF CONCERN <br />1. 1 think the single most important comment I can make on the EIR is what is printed in the <br />Executive Summary of the EIR (pagel-1): <br />"An EIR is a public document designed to provide the governmental agency decision - <br />makers and the public with an analysis of potential environmental consequences". <br />An EIR is not the sole tool that should be used in evaluating a project. Community input, <br />long-term economic and social impacts should also be evaluated. <br />2. OMISSION OF THE MAIN PLACE TRANSFORMATION PROJECT. The EIR omitted looking at the <br />Main Place Transformation Project. The EIR response is: <br />"An environmental impact report's evaluation of cumulative impacts may be based on a <br />list of past, present, and probable future projects producing related impacts (CEQA <br />Guidelines Section 15130(b)(1)(A)). "Probable future projects" include those for which an <br />actual development application has been filed and for which actual environmental review <br />is underway (San Franciscans for Reasonable Growth v. City & County of San Francisco <br />(1984) 151 Cal.App.3d 61, 74). <br />Based on the above, the Draft EIR includes a list of past, present, and probable future <br />cumulative projects for which applications were submitted to lead agencies prior to <br />publishing of the NOP on February 12, 2018." This list forms the basis for the Draft EIR's <br />cumulative impacts analyses. Future projects for which applications were submitted to the <br />City after the NOP was released, such as the Main Place Mall Transformation Project, are <br />therefore not included in baseline conditions or the list of cumulative projects provided as <br />Draft EIR Table 4-1." <br />I contend that since the Main Place EIR was completed in the 1990's it is a known probable <br />future project. When you have two projects at least one of them needs to address the other in <br />its cumulative list. Main Place should have been included in the EIR for the 2525 development. <br />The fact that the new owner of Main Place submitted a new plan in May 2018 is irrelevant. <br />The Main Place EIR did not evaluate the 2525 N. Main Residential Development, therefore the <br />2525 N. Main Residential Development EIR should have evaluated Main Place to ensure <br />cumulative effects were addressed. <br />Page 3 of 17 <br />