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<br />Santa Ana City Council/Community Redevelopment Agency <br />May 15, 1984 <br />Page Three <br /> <br />. <br /> <br />It is no answer to this concern to suggest that environmental <br />review can be supplemented when these plans are finalized <br />at a later date. CEQA requires complete disclosure and con- <br />sideration of the environmental consequences now -- before the <br />Agency has effectively committed itself to the project. This <br />fundamental precept of CEQA doctrine applies with particular <br />force to redevelopment projects such as this, which are intended <br />to be subjected to a single environmental review. (Public <br />Resources Code Section 21090.) <br /> <br />By certifying this EIR and approving the Participation Agreement, <br />the CRA and the Citv'Council would authorize the immediate <br />commencement of acquisitions expected to total $27.5 million. <br />After having made such a major commitment, any additional <br />environmental review would undoubtedly be influenced by <br />potentially serious adverse economic consequences of reversing <br />the prior decision to proceed with the project, Especially <br />where, as here, additional detail concerning the proposed <br />development is currently available to the Agency decision-makers, <br />such detail must be disclosed and analyzed in the EIR. <br /> <br />. I II. IMPROPER RELIANCE ON TRANSPORTATION SYSTE!IS <br /> <br />IMPROVEMENT PROGRAM <br /> <br />The Final EIR is predicated upon the operation of the Trans- <br />portation Systems Improvement Program ("TSIP") entered into' <br />by the City of Orange and Santa Ana in the spring of 1981. In <br />particular, the funding of many of the key mitigation measures <br />is supposed to be derived from the TSIP. (See draft Resolution <br />No. 84-11 (dated May 1, 1984) at page 2.) The improvements <br />noted and prioritized in phase II of the TSIP have not been <br />approved by the City Council of Orange. Further, the TSIP <br />documents, although liberally referenced throughout the EIR, <br />have not been incor~orated therein and, therefore, cannot be <br />relied upon in this' procedure. <br /> <br />. <br /> <br />The EIR fails to disclose that serious questions exist concerning <br />whether or not the TSIP is currently in full force and effect. <br />It appears that Santa Ana has materially breached the TSIP on <br />several occasions. Indeed, it is not even clear if Santa Ana <br />ever appointed its two members to the Joint Planning Review <br />Committee. Nor is there any indication whether Santa Ana has <br />collected, on other projects in this area, the one percent <br />assessment of base construction costs imposed by the TSIP. <br /> <br />\\ <br />