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Jennifer L. Hall June 17, 2025 Page 4 terminating the proposal (i.e., the "no project alternative") and weigh other alternatives in the balance. (Id. at p. 198.) Because CEQA defines "project" as "the whole of an action," an EIR must also describe the entire proposed project-not a piecemeal version. A project description must include future expansion or later phases of a project that will foreseeably result from project approval. (Laurel Heights improvement Assn. v. Regents of Univ. of Cal. (1988)47 Cal.3d 376; 14 Cal. Code Regs., § 15126 [impact analysis must consider all phases of project).) Additionally, the EIR's project description must be internally consistent. If not, it cannot provide a vehicle for informed public participation in the decision-making process. The Addendum fails this standard in multiple respects. Most significantly, it does not account for the discontinuation, decommissioning, or relocation of existing industrial uses that the City determines are "noxious." These industrial operations are currently active within the project area but are expected to be displaced. However, the Addendum does not describe (1) the extent of or number of noxious uses currently operating in the TZC, (2) how these activities may cease and relocate; (3) the future sites for these uses; or (4) whether these displaced uses will be accommodated elsewhere in the City or in nearby jurisdictions. Instead, the Addendum only identifies and discusses environmental impacts attributable to new residential development in the TZC. As discussed above, the Ordinance will have very real environmental impacts outside of the TZC Zone. However, the Addendum relies on an inherently flawed assumption that these purportedly"noxious"uses will just cease to exist without causing any additional impacts or will not relocate to other areas of the City or surrounding areas. In addition to the Madison facility,the Proposed Ordinance also targets a crematorium in the TZC Zone. Even if the City decides to terminate this use in the TZC, the crematorium will necessarily move to another part of the City or beyond. Just because the City declares a use "noxious", does not mean that the use is any less necessary. This failure to adequately describe the Proposed Ordinance and its environmental impacts results in an inaccurate and incomplete project description that dooms the Addendum from the start. Without a legally adequate project description, it is impossible for the public to understand the Proposed Ordinance's environmental impacts or meaningfully participate in the environmental review process. (c) An EIR Must be Prepared Due to a Fair Argument of Significant Environmental Impacts The substantial evidence standard of review does not apply when an agency purports to rely on a program EIR to approve an activity that is not "the same as or within the scope of the