3 - The Bowery_PUBLIC COMMENT_RAMSEY

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City of Santa Ana – The Bowery May 11, 2020 Page 12 of 28 Furthermore, when Mr. Hagemann and Dr. Rosenfeld prepared a simple screening- level HRA, the results demonstrated and provided substantial evidence there may be a significant environmental impact. (Id. at 10-13.) Specifically, “[t]he excess cancer risk posed to adults, children, infants, and during the third trimester of pregnancy at the closest receptor…[is] approximately 68 in one million.” (Id. at 13.) As Mr. Hagemann and Dr. Rosenfeld point out, this figure is well north of SCAQMD’s threshold one in ten million. The DEIR should be amended and include an accurate analysis that analyzes the Project’s health risks relating to air quality. E. The City’s Final Environmental Impact Report Does Not Adequately Describe the Project Generally, an adequate EIR must be "prepared with a sufficient degree of analysis to provide decisionmakers with information which enables them to make a decision which intelligently takes account of environmental consequences." (Dry Creek Citizens Coalition v. County of Tulare (1999) 70 Cal. App. 4th 20, 26.) And while a project’s description can account for needed flexibility to respond to changing project conditions, the description, in any event, needs to be accurate and specific enough to make a reasonable assessment of its sufficiency. (See Citizens for a Sustainable Treasure Island v City & County of San Francisco (2014) 227 Cal. App. 4th 1036, 1053.) A project description that omits integral components of the project may result in an EIR that fails to disclose all of the impacts of the project. (Santiago County Water Dist. v. County of Orange (1981) 118 Cal. App. 3d 818, 829 [project description for sand and gravel mine omitted water pipelines serving project].) As part of the CEQA Guidelines provisions governing the environmental setting, the Guidelines require an EIR to discuss any inconsistencies between the proposed project and applicable general plans, specific plans, and regional plans. (CEQA Guidelines § 15125(d).) An "applicable" plan is a plan that has already been adopted and thus legally applies to a project; draft plans need not be evaluated. (Chaparral Greens v. City of Chula Vista (1996) 50 Cal. App. 4th 1134, 1145 fn. 2.) The purpose of the required analysis is to identify inconsistencies that the lead agency should address. The Project site has an existing General Plan land use designation of Professional and Administrative Office (PAO), and a zoning designation of Light Industrial (M-1). The Project seeks to change these designations through amendments to District Center (DC) and Specific Development (SD), respectively, to allow for a primarily residential mixed-use development.