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<br />7A <br />Page 26 <br /> <br />by the City as an alternative for big-box retail in the certified EIR for the Bayside <br />Gardens project previously proposed for the Century 12 site. It is true that the City has <br />been pursuing the development of an auto sales center for the Century 12 site; however, <br />such a project has not yet materialized, so the site remains available for consideration <br />for other uses. It is appropriate, therefore, under the CEQA statutes and process, for the <br />Century 12 site to be considered as an alternative site for the Costco project. <br /> <br />SOCIAL JUSTICE <br /> <br />Item #11: The issue of social (environmental) justice was raised on the Draft EIR and <br />responded to in the Final EIR, as referenced in the comment (see page 3-86 of the Final <br />EIR). As stated in the Final EIR, environmental justice evaluations are required under <br />the National Environmental Policy Act (NEPA) for federally developed and/or funded <br />projects. The Costco project does not involve federal funds or federal oversight, so <br />environmental justice review is not required under NEPA. <br /> <br />Under CEQA, social effects are not generally considered environmental effects, which is <br />the focus of the statutes. The CEQA Guidelines define the term "significant effect on the <br />environment" as a "substantial, or potentially substantial, adverse change in any of the <br />physical conditions within the area affected by the project including land, air, water, <br />minerals, flora, fauna, ambient noise, and objects of historic and aesthetic significance." <br />With regard to economic and social effects, the Guidelines specifically state that "an <br />economic or social change by itself shall not be considered a significant effect on the <br />environment." This aspect of the Guidelines has been widely interpreted that impacts <br />that are solely economic in nature do not constitute "significant effects on the <br />environment." Nevertheless, CEQA is not exclusively physical in its concern. If an <br />economic impact will cause physical change, as part of a chain of causation, then the <br />physical impact should be considered. The Guidelines state that "economic or social <br />effects of a project may be used to determine the significance of physical changes <br />caused by the project. For example, if the construction of a new freeway or rail line <br />divides an existing community, the construction would be the physical change, but the <br />social effect v'Jould be the basis for determining that the effect vvou!d be significant." <br /> <br />As described in the Draft EIR, the proposed Costco project would not result in any <br />significant unavoidable impacts that cannot be mitigated to a less than significant level. <br />Thus, impacts to surrounding neighborhoods, which were evaluated as being the area <br />where the potential for environmental impacts could occur, would not be significant. <br /> <br />The comment references the Fiscal and Economic Impact Studies that were prepared <br />for the proposed project on behalf of the City, and a possibility of closure of some <br />individual gas stations if the Costco gas station is built. The Economic Impact Study <br />does indicate this, but it also indicates that, based on information from other cities in <br />which Costco has opened gas stations, closures are not inevitable or even likely. The <br />EIR also considered the possibility of gas station closures and determined that in such <br />an event, blight and associated community impacts would not result. The comment <br />further claims that the affected stations would be those closest to the Costco site. There <br />is no conclusive evidence to support this claim. Finally, the comment states that local <br />residents may be "eliminated" from accessing Costco's gas station because one must be <br />a Costco member to buy Costco fuel and some residents may not be "credit worthy" to <br />become a Costco member. Again, there is no evidence in the record to support this <br />claim. <br /> <br />8 <br />