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Honorable Mayor Pulido Santa Ana City Council November 19, 2019 Page 8 For example, the Spring Valley Court found revisions to the air quality impacts analysis, as well as the hydrology and water quality impact analyses "problematic," as the new analyses constituted significant new information requiring recirculation under Section 21902.1. (Spring Valley, supra, 248 Cal.AppAth at pp. 108-109.) As to the air quality impacts analysis, the revisions analyzed the project's consistency with several general plan air quality policies and implementation measures. The Court found as follows with respect to the new information on air quality: As there is insufficient evidence to support the City's finding the project is consistent with these two implementation measures (see pt. I, ante), the information discloses a substantial adverse environmental effect. (Id at p. 108.) Ultimately, the Court found that the revisions constituted significant new information requiring recirculation because their "breadth, complexity, and purpose" deprived the public of a meaningful opportunity to comment on an ostensibly feasible way to mitigate a substantial, adverse environmental effect. (Id. at pp. 108-109; see also Save Our Peninsula Committee v. Monterey County Board of Supervisors (2001) 87 Cal.AppAth 99, 107 (hereafter "Save our Peninsula") ["We conclude that the EIR in this case did not comply with CEQA in its treatment of several critical water issues. Because of these inadequacies, the Board's action certifying the EIR and approving the project constituted an abuse of discretion."]; Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 CalAth 412, 421, as modified (Apr. 18, 2007) [finding that the Draft EIR must be revised and recirculated for public comment].) Similarly here, the FEIR incorporates substantial and significant new information and analyses that must be allowed to undergo further public review. For example, the FEIR with respect to the existing mature trees that the Project proposes to removefor the first time appears to include an Arborist Report as a designed mitigation meas. (See City ure Staff Rept., Oct. 28, 2019, 2-7; see also, id. at p. 2-38 [proposed statement of findings discussing certain Project Design Features "PDFs" that will be implemented like mitigation measures based on the Arborist Report],) This additional measure also purportedly identifies eight trees in an unhealthy condition recommended for removal. (See City Staff Rept., Oct. 28, 2019, 2-7.) The City also acknowledges that this removal will require further review by the Environmental and Transportation Advisory Committee, but that it "will occur at a later date[.]" (See City Staff Rept., Oct. 28, 2019, 2-7.) But, CEQA contemplates a full and complete environmental review that occurs prior to action on the Project —not at some later date after the environmental document has already been certified. If the latter were true, CEQA would be rendered meaningless. Moreover, as the statement of overriding considerations acknowledges, the site could be used by one -special -status wildlife species: the western mastiff bat. (See City Staff Rept., Oct. 28, 2019, 2-57 [draft statement of overriding considerations].) In fact, the 3917.101 / 8509864.1