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8.A. - Page 358 <br />8.A. - Page 116 4, <br />K i ICIP �QLL <br />maneft I PMCM f MAVS <br />Honorable Mayor and Members of the City Coumail <br />August 15, 2011 <br />Page 5 <br />Beaaaw of the inherent confusion that resulta when project-leval envimttmeatai review is <br />conducted in the absence of a Project, the L goslatun has declared tbat it is the poiioy of" state <br />Of California that: <br />L,oca1 agencies fntegrate the reqummants of [CEQA] with <br />planning and onvitm'ial review p�raoadu�res otherwies rcyuir+ad <br />by law or by local practice so drat all those procedures, to the <br />maximum feasible ext nut c m=rrere*, rather them <br />ownc utively. <br />(Pub. Resources Code, §§ 21003(a), c mph. added, see also CEQA Guidelines, § 15004(c) VThr- <br />environmental dooumeat preparation and review should be coordinated in a timely fashion with <br />the existing plawmg, review, and project approval gmcesm s heirs used by each public agency. <br />These procedures, to the maximum extent feast'ble, are m ran counmrently, not COVIOCUtively." j.) <br />While LWANA would prehr the Pknnmg Commis on and City CoUBW to P PUIY cxtt>sider <br />tiro project and the ER together in ace ultra a with the mpmss direction of the L,egWattu+e; <br />becamw the City beta scheduled ttsc appeal of the ER cea'ttf' acaticm for hcMing, in order' to fully <br />preserve in riplrta, LWANA mint submit comments at thin hAarim stage, noiwithStea ft that <br />when a new or revised project application is finally received by rhes City, additional CBQA <br />review of that project will be required and LWANA will again be required to submit ownmenrs <br />in order to p mpmiy preserve its legal rights to ensure The protection of the sunuunding <br />r eighboftods and VWw Eaterald Lake Hills ommunity. <br />3. The tad 1M= Re 2010 <br />Fdk Ta QMVlz Wltb CRQA <br />Basad on our independent legal review and anslysuk including review by sect matter experts, <br />we agree with the conclusion in the Staff Report that the EIR is deficient in two imPOrtmt <br />reapers: (a) the =itigatf on m urm for the awmervus geology -related IMPRcu U0 m8d'c1"e,, <br />and (b) important comparable homing size data (on which parts of the BIR are ba84 ere <br />incorrect and require revision. While ttte two deficiencies identified by Off= saflieient to <br />masa to that the Council uphold LWANA"a weal. additional deficiencies eadst which render <br />the MR inadequate. <br />As detailed be]ow, the EIR falls short of CEQA's msndantory statutory recluirmo ate in sa:vMal <br />key subject matter areas - aesthetes, biology, hydrology, geology, air quality. traffic and noise. <br />The Prancing Coma isWon's conclusion that tha Proposed project would result in "lens than <br />aignificant environmental impacts" is not supported byte required substantial evidcnw in the <br />record. <br />Likewise <br />y the mitigation measures an which the Commiasion's finding of no significant <br />