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0 0 <br />Mr. Steve Worrall <br />January 13, 2012 <br />Page 2 <br />decision makers have been led to believe that the existing lift station had inadequate <br />capacity and that Project objectives were tied to those capacity issues. However, when <br />we noted in comments on the prior EIR that the Project would not provide any additional <br />capacity, the language and objective related to capacity mysteriously disappeared from <br />the RDEIR. (See comment J -6.) When we asked why, the City's response in the RFEIR <br />was essentially "oops. We goofed up. Capacity really isn't inadequate after alI." Now, <br />we and the public are presented with a new Project description and new objectives that <br />are equally suspect and cannot withstand scrutiny. <br />According to the RFEIR's rejiggered Project Description: <br />"The primary objective of the Proposed Project is to provide a <br />new sewage lift station to replace the existing Segerstrom Lift <br />Station, which was originally constructed in the 1960s, most <br />recently upgraded in 1989, and has since exceeded its design <br />life. The exiting lift station is prone to frequent maintenance <br />(two to three times per week) in order to clear blockages due <br />to debris collected in the system. In addition, due to the age <br />of the equipment, the existing pumps are subject to frequent <br />mechanical failures (requiring maintenance), and it is difficult <br />to obtain necessary replacement parts for the facility" (P. 2- <br />6) <br />The new Project objectives are tied to this description of the existing lift station. <br />A review of relevant records, however, shows this description to be both misleading and <br />inaccurate.1 <br />` We also note that although this is a "new" EIR, it is still tied to the prior EIR and <br />administrative process because the Project is the same and the proposed execution of the <br />Project is identical to what was described before. Therefore, the City's shifting of the <br />Project description (in an attempt to bypass valid objections) for the same Project is a <br />separate violation of CEQA that provides independent grounds to invalidate this RFEIR. <br />An incomplete or misleading project description improperly curtails environmental <br />review and the consideration of mitigation measures and project alternatives. "Only <br />through an accurate view of the project may affected outsiders and public decision - <br />makers balance the proposal's benefit against its environmental cost, consider mitigation <br />measures, assess the advantage of terminating the proposal (i.e., the `no project' <br />alternative) and weigh other alternatives in the balance. An accurate, stable, and finite <br />55A -135 <br />