55A - SAN LORENZO SEWER LIFT STATION

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EXHIBIT "A" 1 still would be "0," indicating that this alternative is environmentally equal to the proposed project. EIR Table 5 -1 has been corrected to reflect these revisions. Section VI As was noted in Response J -29 in Section F.3.3 of the Draft EIR, there is no rule in CEQA or elsewhere that the environmental effects of alternatives must be compared in an EIR prior to consideration of mitigation. In Laurel Heights Improvement Assn. of San Francisco, Inc. v. Regents of University of California (1988) 47 Cal.3d 376, 399 -403, cited by the commenter, the CEQA lead agency failed to consider any alternatives to the proposed project after concluding that all significant environmental impacts would be mitigated to a level of insignificance. By contrast, the EIR here examined 21 alternatives to the proposed Project, including 19 alternative site locations. The Supreme Court in Laurel Heights specifically distinguished the situation at issue there, in which an EIR failed to consider any alternatives, from one in which the EIR discussed both alternatives and mitigation measures. (Id. at 402.) The Supreme Court established that the correct analysis in an EIR must include both mitigation measures and alternatives, which, the court noted, "have the same function — diminishing or avoiding adverse environmental effects... alternatives are a type of mitigation." (Id. at 403.) There is nothing about this case that questions an EIR analysis that identifies both mitigation for the significant impacts of the proposed project and also discusses a reasonable number of alternatives. In fact, this approach ensures that decision - makers consider all possible ways to lessen or avoid the impacts of a project as proposed. Section VII The commenter suggests using a submersible pump at the existing lift station as an alternative to the proposed project. The EIR considered retrofitting the existing Segerstrom Lift Station facility. (See Section 5.3.2.) This alternative was rejected from consideration because it would not meet several of the Project's basic objectives. Specifically, it would not allow the City to house electrical equipment above - ground, which means it would not eliminate the issues of the existing lift station being located in Bristol Street. In addition, retrofitting the existing lift station would require upgrades to existing electrical equipment and installation of additional equipment. This would not meet the Project's objective to "Provide a lift station facility that provides sufficient access space for maintenance of the lift station facility." Moreover, such an alternative would fail to meet the Project's objective to construct a replacement lift station facility located outside of the public rights -of -way so as to minimize potential safety conflicts between motorists and maintenance personnel. Finally, such an alternative would not achieve the Project's objective to construct a new lift station facility, as this alternative would not involve the construction of a new lift station but rather would involve upgrades to the existing facility. For these reasons, using a submersible pump at the existing lift station is not a feasible alternative to the proposed project. 55A -129