Correspondence - Item 20 (3) - Laserfiche WebLink

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Jennifer L. Hall June 17, 2025 Page 3 Addendum fails to consider the indirect and cumulative effects of displacing"noxious" industrial uses, including their relocation to other parts of the City or surrounding communities. This relocation could lead to increased vehicle miles traveled (VMT), emissions, and congestion in areas that are not addressed in the Addendum. CEQA requires a complete and accurate analysis of both direct and foreseeable indirect impacts. By ignoring the consequences of industrial displacement, the Addendum understates the project's true environmental impacts across the City and surrounding areas. The Addendum's deficiencies in this respect are highlighted in its discussion of the full build out scenario. There, the Addendum only discusses the impacts associated with increased residential uses,but provides no explanation or discussion of the potential impacts associated with the displacement of the industrial uses those residences will necessarily displace. As a result, the Addendum and 2010 EIR are entirely devoid of any environmental analysis related to impacts associated with the relocation or closure of these "noxious" environmental uses. Without any discussion of these impacts, the City Council cannot make a reasonably informed decision on the Ordinance's environmental impacts and the public is similarly kept in the dark. For example, any discontinuation of use at the Madison facility may result in substantial environmental impacts throughout the City. Currently, Ware, as well as a number of other solid- waste haulers, rely on the Madison facility to deliver solid waste collected in the surrounding community. Trash collection and disposal services are a necessary component of human habitation and the orderly sorting and disposal of solid waste is mandated by state law. As such, it is certain that facilities like Madison will have to relocate to different parts of the City or surrounding areas. Even without the Madison facility, these haulers will be forced to travel to Anaheim or Santa Fe Springs to make deliveries that were otherwise available within the City. This will necessarily result in increased truck traffic and emissions in other parts of the City and surrounding areas, which impacts were not otherwise analyzed in the Addendum. (b) The Addendum's Project Descrikition is Fatally Deficient An accurate project description"is the sine qua non of an informative and legally sufficient EIR." (County of Inyo v. City of L.A. (1977)71 Cal.App.3d 185, 193, 199 (hereafter County of Inyo).) When a proposed project is accompanied by an inaccurate or incomplete description, it undermines CEQA by drawing "a red herring across the path of public input." (Id. at pp. 193, 199.) A court will reject an EIR with an incomplete or inaccurate project description because, as the court stated in County of Inyo: Only through an accurate view of the project may affected outsiders and public decisionmakers balance the proposal's benefit against its environmental cost, consider mitigation measures, assess the advantage of