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City of Santa Ana <br />4th and Mortimer Project <br />Response 22 <br />The commenter states that the City's decision to prepare an addendum instead of an EIR is not <br />supported by evidence and adds that approval of the project based on the Addendum would <br />constitute an abuse of the City's discretion. The commenter also states that the City may not rely on <br />the 10-year 2010 FEIR and requests that the Planning Commission decline to recommend the City <br />Council approval of the Addendum and, instead, direct Planning Staff to prepare and circulate an EIR <br />for public review. <br />As discussed 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 CEQA. Furthermore, as discussed in Response 7, to <br />support the use of the 2010 FEIR and that the 2010 FEIR retains relevance and has "some <br />informational value," the City may rely on evidence of the similarities in the project to the approved <br />project analyzed in the 2010 FEIR, and does not have to necessarily show that the impacts from the <br />project were analyzed in the 2010 FEIR or that the 2010 FEIR adequately analyzed the approved <br />project with the proposed changes under current CEQA standards. <br />75C-296 <br />