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MainPlace Transformation Project City Council Agenda Item 75D June 4, 2019 Page 15 and 995 fewer PM peak hour trips that would the 1983 project. Smith, p. 2. However, Mr. Smith explains, if the Addendum had compared the Project's trip generation to the trip generation listed in the 1983 EIR, an opposite conclusion would be reached. The 1983 EIR estimates a trip generation of 57,245 daily trips for the 1983 Project. This is 10,056 daily trips than the Addendum estimates the 1983 Project would generate. Moreover, using the 1983 EIR's estimate, the currently proposed Project would result in 3,805 more PM peals hour trips than the 1983 Project. Smith, p. 2. The conclusion that the Project would result in no worse traffic impact than what was analyzed in the 1983 EIR is incorrect. The conclusion that the proposed Project would result in no worse traffic conditions than the 1983 Project is the result of introduction of new information that was not known and could not be known at the time of the 1983 EIR. D. There is no Evidence to Support the Addendum's Conclusion that the Project Will Not Result in Impacts to Public Services Because the Addendum Does not Analyze the Need for New or Expanded Schools. According to Appendix G of the CEQA Guidelines, a project may have a significant impact on public services if it would result in the need for new or expanded schools that may cause a significant environmental impact. CEQA Guidelines, App. G, section XV. The Project includes 1,900 residential units that were not previously analyzed. While the Addendum never discloses how many people are expected to occupy the residential portion of the Project, the climate change analysis uses the California Department of Finance population estimate of 2.9 people per household, which would amount to an additional 5,510 residents living at the Project site. See Addendum, Appendix H, p. 32. Some portion of these new residents will be children, and those children will attend schools. An analysis is needed to determine if the additional 5,510 residents will result in a significant impact because of the need for new or expanded schools. Instead, the Addendum ignores this issue entirely. Without any analysis of the Project's impacts on schools, the Addendum's conclusion that the Project will not have a significant new impact on schools is not supported by substantial evidence. V. The Project Description is Inadequate to Evaluate Environmental Impacts. The adequacy of an EIR's project description is closely linked to the adequacy of the EIR's analysis of the project's environmental effects. As a result, one of the important requirements of CEQA is that the project description not be confusing, shifting, or open- ended. This is to ensure that project impacts are analyzed properly and accurately. "An accurate, stable and finite project description is the sine qua non of an informative and legally sufficient EIR." County oflnyo v. City of Los Angeles (1977) 71 Ca1.App.3d 185, 193. One aspect of the project description that is particularly important to determining a residential project's environmental impacts is the number of people expected to live in a new housing development. Many environmental impacts are dependent on the number of residents,