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DOWDALL LAW OFFICES A PROFESSIONAL CORPORATION ATTO R N EYS AT LAW City Council of the City of Santa Ana City of Santa Ana September 16, 2021 Page 22 18. The rent law will affect housing and will create additional demand for affordable rental housing which cannot be met by Los Angeles. If the city chooses to recommend passage of this proposal, an FIR is required in order to assess the environmental impact of massive decline in property maintenance standards and customs, together with the impacts of pursuit of administrative relief seeking avoidance of confiscatory effects and preservation of a fair return. An EIR must be prepared if a project (here a proposed rent control ordinance) has a significant, adverse growth -inducing impact. If the effect on management operations and commuter distances for large numbers of semi -change in occupational workers in older automobiles that pollute more than newer or electric automobiles are considered, the totality of the effect may in turn cause adverse environmental consequences. If these effects could be significant, an FIR rather than a Negative Declaration must be prepared. Even if the precise form, location, and amount of induced development is unknown, an FIR must still be prepared if it can assume a reasonable form, location, and amount of development. (1 California Environmental Law & Land Use Practice § 21.09 (2020)) For example, an economic or social change related to a physical change may be considered in determining the significance of the physical change. ' The Guidelines identify two ways in which economic and social changes may be used to determine whether a physical change is a significant environmental effect. 6 -First, when a physical change is caused by the intervening economic or social effects of a project, the physical change may be regarded as a significant environmental effect. For example, physical deterioration of a downtown area caused by economic decline may be a significant environmental effect of approval of an outlying shopping center.' s 14 Cal. Code Reg. §§ 15064(f)(6), 15382; see Friends of Davis v. City of Davis (2000) 83 Cal. App. 4th 1004, 1020, 100 Cal. Rptr. 2d 413 (identity of bookstore tenant not considered significant environmental effect); Citizen Action to Serve All Students v. Thornley (1990) 222 Cal. App. 3d 748, 758, 272 Cal. Rptr. 83; Cathay Mortuary, Inc. v. San Francisco Planning Com. (1989) 207 Cal. App. 3d 275, 254 Cal. Rptr. 778 (cultural impacts must be tied to physical impacts to fall within CEQA). ' 14 Cal. Code Reg. § 15064(e). For a review of the treatment of economic and social effects in EHZs, see § 22.04[6][c]. ' Citizens Assn. for Sensible Development of Bishop Area v. County of Inyo (1985) 172 Cal. App. 3d 151, 169-171, 217 Cal. Rptr. 893; see Placerville Historic Preservation League v. Judicial Council of California (2017) 16 Cal. App. 5th 187, 197, 223 Cal. Rptr. 3d 637 (urban decay not reasonably foreseeable indirect effect of project to move courthouse from historic downtown); Anderson First Coalition v. City of Anderson (2005) 130 Cal. App. 4th 1173, 30 Cal. Rptr. 3d 738 -22-