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Responses to Comments on the EIR Addendum B. Significant effects previously examined will be substantially more severe than shown in the previous EIR; C. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or D. Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative. According to CECtA Guidelines Section 15164 (Addendum to an EIR or Negative Declaration), the lead agency shall prepare an addendum if none of the conditions specified in CEQA Guidelines Section 15162 are met. Primarily, Section 3, Environmental Impact -Analysis, of the Addendum supports the conclusion that changes to the proposed project would not result in new or more severe impacts than those of the approved project disclosed in the previously certified 2010 FEIR and would not require a major revision to the 2010 FEIR. The Addendum also includes applicable mitigation measures identified in the 2010 FEIR. Therefore, the City is within its discretion to proceed with an addendum as the appropriate environmental document for the project under CECA. In addition, the comment does not provide any specific examples of where analysis within the Addendum is inadequate, where additional information is needed, what mitigation measures are excluded, or what impacts are new and different than those analyzed in the 2010 FEIR. The commenter does provide additional detail to their claims further into the comment letter and, therefore, individual responses to each claim are provided based on order of appearance throughout the remaining responses of this section. Response 2 The commenter identifies experts that have reviewed the project, including certified Industrial Hygienist, Francis "Bud" Offermann, PE, CIH; and Dr. Paul Rosenfeld, Ph.D. and Matthew Hagemann, C. Hg. of Soil Water Air Protection Enterprise (SWAPE). The commenter generally states that these experts have identified significant impacts associated with the project's air quality impacts and have identified omissions and flaws in the documents relied upon by City Staff. This comment and the identified experts' separate analyses, which are attached as Exhibits A and B to the comment letter, are acknowledged but do not raise specific concerns regarding the project's air quality impacts or other alleged flaws in the Addendum and associated documents. Responses to the commenter's concerns based on the findings of Mr. Offermann and SWAPE are provided in Responses 10 through 12 and Response 18, respectively, of this section. Response 3 The commenter states that use of an addendum instead of an EIR or supplemental EIR deprived the public from a public review period and other circulation requirements associated with EIRs. On behalf of SAFER, the commenter asks that the City not adopt the Addendum or otherwise approve the project and, instead, direct City Staff to prepare an EIR for public review circulation and comment prior to approval. As described in Response 1, the project did not require a subsequent or supplemental EIR or negative declaration because none of the conditions described in PRC Section 21166 and CEC1A 75C-287