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MainPlace Transformation Project City Council Agenda Item 75D June 4, 2019 Page 11 supplemental EIR if the changes are "[s]ubstantial" and require "major revisions" of the previous EIR. Friends of Coll. of San Mateo Gardens v. San Mateo Cty. Cmty. Coll. Dist. (2016) 1 Cal.5th 937, 943. "[W]hen there is a change in plans, circumstances, or available information after a project has received initial approval, the agency's environmental review obligations "turn[ ] on the value of the new information to the still pending decisionmaking process." Id., 1 Cal.5th at 951-52. The agency must "decide under CEQA's subsequent review provisions whether project changes will require major revisions to the original environmental document because of the involvement of new, previously unconsidered significant environmental effects." Id., 1 Cal.5th at 952. Section 21166 and CEQA Guidelines § 15162 "do[] not permit agencies to avoid their obligation to prepare subsequent or supplemental EIRs to address new, and previously unstudied, potentially significant environmental effects." Id., 1 Cal.5th at 958. All of the evidence indicates that the project considered by the 1983 EIR has undergone significant changes to the project and its circumstances requiring substantial revisions to that 35- year old EIR. A. A New EIR is Required Because the Addition of 1,900 Residential Units is a Substantial Change from the 1983 Project and there is Substantial Evidence that the Residential Element of the Project Will Result in Emissions of Formaldehyde to the Air that Will Have a Significant Health Impact on Future Residents. Even if the 1983 EIR was somehow relevant to the current Project, the City would still be required to prepare an SEIR. The inclusion of 1,900 new residential units as part of the Project is a substantial change from the 1983 project. "The purpose behind the requirement of a subsequent or supplemental EIR or negative declaration is to explore environmental impacts not considered in the original environmental document." Friends of College of San Mateo Gardens v. San Mateo (2016) 1 Cal.5th 937, 949 (quoting Save Our Neighborhood v. Lishman (2006) 140 Ca1.AppAth 1288, 1296). As discussed above, the expert opinion of Mr. Offermann constitutes substantial evidence that the residential component of the Project will result in a significant air quality impact to residential occupants of the Project. This impact is significant and new. It could not have been known in 1983 because there was no residential element of the Project at that time. Accordingly, the City violated CEQA by not preparing an SEIR to analyze and mitigate this new significant impact. There is no substantial evidence in the record to support a conclusion that the Project will not have a new significant indoor air quality impact as a result of significant changes to the Project when compared to the project analyzed in the 1983 EIR. Accordingly, the City's decision to prepare an Addendum rather than an SEIR is not supported by substantial evidence, and approval of the Project based on the Addendum would constitute an abuse of discretion.