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The Bowery Mixed -Use Project CEQA Comment May 11, 2020 Page 4 participation, thereby thwarting the statutory goals of the EIR process." (San Joaquin Raptor/WildlifeRescue Center v, County ofStanislaus (1994) 27 Cal.App.4th 713, 722; Galante Vineyards v. Monterey Peninsula Water Management Dist. (1997) 60 Cal. App. 4th 1109, 1117; County ofAmador e E1 Dorado County Water Agency (1999) 76 Cal. App. 4th 931, 946.) More recently, the California Supreme Court has emphasized that: When reviewing whether a discussion is sufficient to satisfy CEQA, a court must be satisfied thatthe EIR (1) includes sufficiclrt detail to enable those who did not participate in its preparation to understand and to consider meaningfully the issues the proposed project raises [citation omitted].... (Sierra Club v. Cry. of Fresno (2018) 6 Cal.5th 502, 510 (2018), citing Laurel Heights Improvement Assn. v Regents of University ofCaliforrrio (1988) 47 C31.3d 376, 405.) The Court in Sierra Club v. Cty, of Fresno also emphasized at another primary consideration of sufficiency is whether the EIR "makes a reasonable effort to substantively connect a project's air quality impacts to likely health canscquences." (6 Cal5th A 510.) `Whether or not the alleged inadequacy is the complete omission of a required discussion or a patently inadequate one - paragraph discussion devoid of analysis, the rcvicwing court must decide whether the t,IR serves its purpose as an informational document." (Id. at 516.) Although an agency has discretion to decide the manner of discussing potentially significant effects in an EIR, "a reviewing court must determine whether the discussion of a potentially signi.ficard effect in sufficient or iusul)iciem, i.e., whether the EIR comports with its intended function of including `detail sufficient to enable those who did not participate in its preparation to understand and to consider meaningfully the issues raised by the proposed project."' (6 Cal.5tb at 516, citing Bakersfield Citizens for Local Control v. City gfBakersfreld (2004) 124 Cal.App.4th 1184, 1197.) "Me determination whether a discussion is sufficient is not solely amatter of discerning whether there is substantial evidence to support the agency's factual conclusions." (6 Cal.5th at 516.) As the Court emphasized (Sierra Club v. Cty. of Fresno, 6 Cal.5th at 514.): [W]hether a description of an envircrunental impact is insufficient because it lacks analysis or omits the magnitude of the impact is not a substantial evidence question. A conclusory discussion of an environmental impact that an EIR deems significant can be determined by a court to be inadequate as an informational document witbom reference to substantial evidence_ In general, mitigation measures must be designed to minimize, reduce or avoid an identified environmental impact or to rectify or compensate fOr that impact_ (CEQA Guidelines § 15370.) Where several mitigation measures are available to mitigate an impact, each should be discussed and the hasis for selecting a particular measure should he identified. (Id. at § 15126.4(a)(1)(B).) A lead agency may not make the required CEQA findings unless the administrative record clearly shows that all uncertainties regarding the mitigation of significant environmental impacs have been rcgWved_ 75C-20