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Honorable Mayor Pulido <br />Santa Ana City Council <br />November 19, 2019 <br />Page 9 <br />species has a "the site could be used by one special -status wildlife species, the western <br />mastiff bat, that has a low potential to roost in the large trees and palms[,]" many of <br />which are being removed for the first time in the FEIR due to a new mitigation measure <br />and Arborist's Report designating certain existing trees and palms as unhealthy and <br />qualified for removal. (See City Staff Rept., Oct. 28, 2019, 2-57 [draft statement of <br />overriding considerations].) Overall, the FEIR fails to adequately address significant <br />concerns raised by state and federal agencies, independent scientists, conservation <br />organizations, tribal representatives, and members of the public directly affected by this <br />new mitigation measure. As a result of these and other related deficiencies, the FEIR <br />may fail to fully inform the public and decision -makers of the Project's significant <br />environmental impacts and to analyze and/or mitigate these impacts in accordance with <br />CEQA. <br />Failing to recirculate given these changes to the most significant and unavoidable <br />impacts would result in an inability of the public or agencies to meaningfully comment <br />on the Project's environmental impacts. The City should thus allow the FEIR to be <br />recirculated and evaluated. <br />6. CONCLUSION. <br />The adequacy of an EIR's project description is inextricably linked to the adequacy of its <br />analyses of environmental effects. If the description, baseline, and consistency <br />requirements are not met, the resulting environmental analyses will reflect the same <br />mistakes. This is particularly true in situations like those at issue here, where the <br />Project as originally envisioned is entirely different from the one presently before the <br />City Council. Once a new EIR is prepared, then additional substantive issues may be <br />raised and addressed. PSNA reserves its rights to submit further public comment at <br />and up to the close of the record on the Project and requests formal, written notice in <br />advance of any future meetings or notices of determination related to the Project. For <br />the foregoing reasons, among others, PSNA respectfully requests that the City Council <br />deny the proposed Project, consistent with the Planning Commission's recommendation <br />below. <br />3917.101 18509864.1 <br />