July 16, 2024
Dear Mayor and City Council:
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These are my concerns about the City's reliance on an addendum to an environmental impact report for the project changes and the proposed election up for consideration as Items 18 and 19 on your agenda for tonight. I believe that you are violating the California Environmental Quality Act in several ways.
The addendum was not circulated for public comment and its existence was not known to the public until notice of the public hearing was published-on the 4th of July holiday -so the public has not had adequate time to digest its contents (more than 2,500 pages). You should delay your consideration of these two items until the public has had a reasonable opportunity to review the addendum and to comment on it.
There is insufficient evidence to support a finding that the addendum reflects the City's independent judgment. It appears that someone other than the City commissioned and/ or paid for the addendum.
Evidence in the addendum shows a need to prepare a supplemental, subsequent, or other environmental impact report (EIR) due to traffic impacts. In Attachment D, the LLC Trip Generation Memorandum, Table 3 indicates that a delay over one second at an intersection having an "F" level of service is significant. Table 5 indicates that there will be more than a one-second delay at intersection 1 7. This means that the City should be preparing some sort ofEIR and not relying on an addendum.
Plus, the significant increase in traffic delay means that the project applicant must then identify feasible improvements that will restore or maintain the traffic facility at an acceptable level of service. However, the addendum does not propose any improvements or other mitigation measures compared to what was approved in the original BIR. The City is using old mitigation while ignoring a new problem.
Thank you for your consideration.