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Honorable Mayor Pulido Santa Ana City Council November 19, 2019 Page 6 4. ULTIMATELY, THE CITY MAY BE RESPONSIBLE FOR THE INADEQUATE FEIR. CEQA compliance must occur before the City approves the Project. When a public agency gives a project "approval" it "commits to a definite course of action in regard to a project." (CEQA Guidelines, 14 Cal. Code Regs., § 1532, subd. (a).) In Save Tara v. City of West Hollywood (2008) 45 CalAth 116, 130-132, the Court struck down a project, finding that the city violated CEQA because it had impermissibly committed itself to the project before completing an adequate CEQA review. While an applicant's consultant may prepare an EIR, that does not relieve the City from its independent duty to review and exercise judgment over the document. Indeed, the City must independently review, evaluate, and exercise judgment over the document and the issues it raises and addresses. (Friends of La Vina v. County of Los Angeles (1991) 232 Cal.App.3d 1446, 1452; Pub. Res. Code, § 21082.1.) Ultimately, the City will be the one left holding the bag for certification of an inadequate EIR. (Mission Oaks Ranch, Ltd. v. County of Santa Barbara (1998) 65 Cal.AppAth 713, 723-724.) Here, the adequacy of the FEIR's Project description is inextricably linked to the adequacy of its analyses of environmental effects. If the description, baseline, and consistency requirements are not met —the resulting environmental analyses will be similarly flawed. (See Laurel Heights, supra, 47 Cal.3d 376 [EIR failed to describe or analyze project accurately].) For example, if an EIR bases its cumulative impact analyses on general plan projections, it must explain why these projections function as a realistic predictor of related impacts. (See 14 Cal. Code Regs. § 15130, subd. (b)(1)(B).) Moreover, a general plan's projections of future growth and related impacts are an inadequate basis for an EIR's cumulative impact analysis if the plan's projections do not cover a sufficiently wide area or exclude relevant data. (See Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692 [no explanation of why analysis of cumulative air quality impacts was limited to Central Valley]; Citizens to Preserve the Ojai v. County of Ventura (1985) 176 Cal.App.3d 421 [air quality analysis defective for failure to include contribution to pollution from offshore oil operations].) This is particularly true in situations like those at issue here, where the Project was originally envisioned at a higher density. Because the FEIR may rely on inaccurate estimates of projected development density, the analyses that flow from that estimate may be similarly flawed. In addition to the potential issues identified in this comment and the various additional comments submitted, the FEIR also may fail to identify, discuss, or mitigate potential significant impacts in the transportation and circulation section. For example, back-up of southbound traffic on N. Main Street between Edgewood Road and Walkie Way has the potential to significantly increase traffic and block intersections. The Project is proposing to reduce the distance between these intersections, while adding traffic to the back-up of traffic. In the technical studies for the project, information is calculated that 3917.101 ( 8509864.1