Item 18 - Appeal Application Nos. 2023-02 and 2023-03 for Cabrillo Town Center project

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Appeal — Cabrillo Town Center Mixed -Use Development Project May 3, 2023 Page 11 of 12 Efficiency Standards. Thus, a subsequent EIR should have been prepared to specify and incorporate these additional feasible mitigation measures. C. The Project May Have Significant Land Use Impacts Which Were Not Analyzed in the Metro EIR Yet another reason why a subsequent EIR should have been prepared is because the Project may have significant unanalyzed land use impacts stemming from the Project's request for a tentative tract map ("TTM"). Specifically, the Metro EIR provides that the: project approvals include certification of the EIR for the proposed project, as well as adoption of the Overlay Zone and associated General Plan Amendment and Zone Change. This EIR is intended as a Program EIR, and specific developmentproposals made in the Overlay Zone would be subject to separate environmental clearance) review. Metro EIR at 3-17. Thus, a subsequent EIR which specifically analyzes the Project's TTM request in its land use consistency analysis is necessary. Additionally, the Project runs afoul to the General Plan since it fails to provide any affordable housing units. One policy of the General Plan is to "encourage private and commercial recreational facilities that are physically open to the public and are affordable to residents of surrounding neighborhoods". General Plan, Policy OS-1.10. Similarly, the General Plan provides that the City must "explore development and subdivision options that promote new opportunities for sustainable, livable, and affordable development." General Plan, Policy UD-2.8. As the Project at hand provides no affordable housing units, it conflicts with the General Plan. For this reason too, the City should have prepared a subsequent EIR to assess the Project's land use impacts. V. CONCLUSION In sum, SMSWRCC maintains that the City should require a local workforce, that the City should impose training requirements for the Project's construction activities to prevent community spread of COVID-19 and other infectious diseases, and that the City should have prepared a subsequent EIR for the Project addressing the aforementioned concerns to be CEQA compliant. If the City has any questions, feel free to contact my office. City Council 18 — 28 10/3/2023