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�� „�� 8.A. - Page 117 11 manatt [ phelps � phillips Honorable Mayar and Members of the City Council August 15, 201 l Page 6 iinpact was purportedly based, are insufficient and unrealistic — in shnrt, they do not lessen to an "insignificant' level the irreparable environme�ntal da�nage, devastation and risks resulting from this project. Accordingly, we respectfiilly request the City Counci! ta reverse the Planning Commission's cer�ification of the EYR, and ame�d iks findii3gs accordingly. (a) The EIR's Proiect Descrintion Is IMadepaate, (�) There Must Be A Praiect Befare CEOA Review Can Be Conduc�ed CEQA requires that a project description be accnrate, stable ai�d finite and include precise locatianlboundarie�, a clear statement of project abjectives and general description of the project's technical, ecc�nomic a�id enviror�rnental characteristics. (County of Inyo v. City of Los Angeles (1977} 71 Ca1.App.3d 185, 132; CEQA Guidelines, § 15124.) B�cause the appIicanl valuntarily withdrew its �applicatian �ar entitlernents on March 22, 201 I, the prolect descri�tion contained in the EIR satisfies none of these requixcments. In short, ii� the absence of a project application, there is no proiect d7at can be evaivated under CEOA. It is ��ot known at this time what exactly will be proposed for de��lopment or eve:n the acreage of the praject site itself Without a c�escription of the project (because the application has been withdrawn and we ca.�ulat speculate as ta what will be proposed in the future), we are unab2e to evaluate whether tne ETR has failed to disclose impaets of the project. (See, e.g., Santiago Courary Water Dr'st. v. County of Orange (1981) 118 Cal.App.3d 818, 829.) Whi1e we ha�e an idea of what was proposed in the past, no inteIligent eva.luation of the potential en�ironmental effects of the project can be conducted until rve knaw wl�at is now proposed. (San Joaquin Raptor/�ldlife Rescue Ctr. v. County of Stanislaus (1994) 27 Ca1.App.4th 713, 730.} Significant questions remain unansw�red. �or example, �vhen the project is r��iled (as we presume it will be eventually) will the projcct boundaries be significantly a.�tered due ta the exclusion of three of the lots the applicant had inc1uded in the originai pro}ect application7 Wi�l the applicant propose a new subdivision, or some sort of lot merger and lot line adjustment o� up to 20 individuaI lots? Will the road be rec}uired to be widene.d to 50 feet as required by the original suhdivision map (see Highlands of Emerald Lake, Subc3ivision One, Shee� Faur}? Will an apen space easement or consarvation easement �e dedicated in the creek bed, and wha wi11 accept ar hold that easement in perpetutity? In the absence of a project application, the list of , unanswered questians is infinite. The City's own outside land use counsel confirms that the lack of a project is concerning: Under the present circumstances, there are certain practical difficulties with the City Council considering certification af the