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Responses to Comments on the EIR Addendum <br />and massing originally analyzed in the 2010 FEIR. The commenter concludes that the project is a <br />new project that has not undergone CEQA review and "must start from the beginning of the CEQA <br />process" with an initial study prior to approval. <br />The 2010 FEIR retains both relevance and informational value to the proposed project. Courts may <br />only reject an agency's use of a previously certified EIR if it is "wholly irrelevant." As discussed in <br />Response 1, Section 3, Environmental Impact Analysis, of the Addendum supports the conclusion <br />that changes to the project would not result in new or more severe impacts than those of the <br />approved project previously disclosed in the 2010 FEIR and would not require a major revision to <br />the 2010 FEIR. Therefore, the City shall proceed with an addendum as the appropriate <br />environmental document for the project under CEQA. <br />Response 8 <br />The commenter summarizes the 2010 FEIR's significant and unavoidable impacts (i.e., those related <br />to Aesthetics, Air Quality, Cultural Resources, Noise, and Traffic) and, based on a reference to case <br />law, adds that the City is required to conduct project -level supplemental EIRs for specific projects <br />proposed in the program area to analyze and determine whether mitigation measures exist to <br />reduce these significant and unavoidable impacts. <br />As described in Response 1, the project does not require a subsequent or supplemental EIR or <br />negative declaration because none of the conditions described in PRC Section 21166 and CEQA <br />Guidelines Sections 15162 and 15164 were met to trigger the need for these documents. Although <br />the 2010 FEIR identified significant and unavoidable impacts, the question is whether the project <br />analyzed in an addendum would result in new or more severe impacts than those of the approved <br />project. Section 3, Environmental Impact Analysis, of the Addendum supports the conclusion that <br />changes to the project would not result in new or more severe impacts, including those related to <br />Aesthetics, Air Quality, Cultural Resources, Noise, and Traffic, with implementation of applicable <br />mitigation measures identified in the 2010 FEIR and included in the Addendum discussion. Appendix <br />K to the Addendum includes the Mitigation Monitoring and Reporting Program (MMRP) of the 2010 <br />FEIR for reference. <br />Response 9 <br />The commenter states that, even if addendum provisions under CEQA applied to the project, a <br />supplemental EIR would still be required to analyze new significant impacts of the project resulting <br />from changes to the approved project and new impacts that were not analyzed in the 2010 FEIR. <br />As described in Response 1, the project did not require a subsequent or supplemental EIR or <br />negative declaration because none of the conditions described in PRC Section 21166 and CEQA <br />Guidelines Sections 15162 and 15164 were met to trigger the need for these documents. Primarily, <br />Section 3, Environmental Impact Analysis, of the Addendum supports the conclusion that changes to <br />the project would not result in new or more severe impacts than those of the approved project <br />previously disclosed in the 2010 FEIR and would not require a major revision to the 2010 FEIR. <br />Therefore, the City is within its discretion to proceed with an addendum as the appropriate <br />environmental document for the project under CECA. <br />75C-289 <br />