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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 23 .Second, economic and social effects caused by a physical change may be used to determine that the physical change is a significant environmental effect. For example, evidence that siting of solid waste facilities near a religious retreat would disturb religious practices may be used to determine whether construction and use of the solid waste facilities would be significant environmental effects.' Examples of socioeconomic effects that do not constitute physical environmental effects under CEQA include: -School overcrowding, unless causally tied to physical changes such as the need for construction of additional classrooms. v -Disagreements among different users of recreational facilities. 10 -Safety issues associated with private playground recreational equipment. Eureka Citizens for Responsible Government v. City of Eureka (2007) 147 Cal. App. 4th 357, 377, 54 Cal. Rptr. 3d 485. " -Fear of lowered property values caused by a proposed project. Porterville Citizens for Responsible Hillside Development v. City of Porterville (2007) 157 Cal. App. 4th 885, 903-904, 69 Cal. Rptr. 3d 105; see also Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal. App. 4th 1184, 1205,22 Cal. Rptr. 3d 203. -Fear of vandalism associated with a parole office. City of Pasadena v. State of California (1993) 14 Cal. App. 4th 810, 830, 17 Cal. Rptr. 2d 766. (EIR urban decay analysis adequate); Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal. App. 4th 1184, 1204, 22 Cal. Rptr. 3d 203 (EIR urban decay analysis inadequate). e See Christward Ministry v. Superior Court (1986) 184 Cal. App. 3d 180, 197, 228 Cal. Rptr. 868. 9 Goleta Union School Dist. v. Regents of University of California (1995) 37 Cal. App. 4th 1025, 1032, 44 Cal. Rptr. 2d 110. " Lighthouse Field Beach Rescue v. City of Santa Cruz (2005) 131 Cal. App. 4th 1170, 1206, 31 Cal. Rptr. 3d 901 (dog park opponents failed to produce any substantial evidence of physical effects). " Eureka Citizens for Responsible Government v. City of Eureka (2007) 147 Cal. App. 4th 357, 377, 54 Cal. Rptr. 3d 485. -23-