7 - COMBINED PUBLIC COMMENTS - Laserfiche WebLink

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3. The EIR needed far more than only minor technical changes or additions to make the 1983 EIR adequate under CEQA for this Project. This is evidenced by the fact that the Addendum in nearly 3,000 pages, more than ten times as large as an average addendum under CEQA. Had the Project only required minor or technical changes to the 1983 EIR, a 3,000-page addendum would not have been required. 4. The 1983 EIR included many mitigation measures that were never implemented, including traffic mitigation measures. Since the City has failed to implement the mitigation measures required by the EIR, it may not now rely on that document. See, Katzeff v. Dept. of Forestry (2010) 181 Cal.App.4th 601, 611, 614; Lincoln Place Tenants v. City of Los Angeles (2005) 130 Cal.App.4th 1491, 1507 n22. 5. There are numerous changed circumstances that have occurred since 1983 that require renewed environmental review. For example, traffic in the area is much heavier than in 1983. 6. By opting to proceed with an Addendum instead of the required EIR or supplemental EIR, the City has deprived the members of the public of the public review and circulation requirement available for EIRs. Release of the Addendum only days prior to the Planning Commission’s hearing to recommend its approval, SAFER and other members of the public had little time to review the 3,000 page document. SAFER and their experts will provide additional comments on the inadequacy of the Addendum prior to the City Council’s hearing. For the above and other reasons, the Planning Commission should decline to recommend the City Council approve the Addendum, and instead direct Planning Staff to prepare and circulate an EIR for public review. The City may not rely on the nearly 40- year old 1983 EIR. Sincerely, Rebecca Davis