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May 6, 2021 <br />Page 22 <br /> <br /> <br />5005-003acp <br /> <br /> printed on recycled paper <br />Our traffic expert determined that the Project will have significant adverse <br />impacts on traffic and create demands exceeding the capacity of public services and <br />facilities94, these cannot be mitigated by the proposed Uniformly Applicable <br />Development Standards laid out in the General Plan.95 Our expert determined that <br />the Checklist failed to disclose potentially significant cumulative effects that are <br />specific to the Project, but were not analyzed, and are more severe than, the traffic <br />issues raised in the General Plan EIR.96 An Infill EIR must be prepared to <br />adequately address and mitigate impacts from traffic prior to Project approval by <br />the Board. <br /> <br />C. The Uniformly Applicable Development Standards Would Not <br />Substantially Mitigate Project Impacts <br /> <br />Our experts determined that the uniformly applicable development policies <br />would not substantially mitigate the impacts from air quality, energy usage, GHG <br />emissions, noise, traffic, and water quality. <br /> <br />i. Air Quality <br /> <br />The Project is not consistent with the General Plan because General Plan <br />Policy 31.04 provides that the City must “Require new development to be designed <br />and constructed in a way that reduces the potential for future air quality problems, <br />such as odors and the emission of any and all air pollutants.”97 The Board therefore <br />cannot approve the Conditional Use Permit due to the inconsistency with the <br />General Plan policy. Further, the mitigation measures presented in the General <br />Plan and Checklist would not substantially mitigate the impacts of the Project. <br /> <br />a. Tier 4 Interim Measures <br /> <br />The Checklist does not ensure that best available control technologies are <br />used for operations that could generate air pollutants as required by General Plan <br />Policy EH-3.4.98 Further, the use of Tier-4 Interim mitigation measures does not <br />constitute sufficient mitigation. As SWAPE describes in their comments, Tier 4 <br />Interim measures do not constitute adequate mitigation because they do not go <br /> <br />94 Smith Comments p. 6. <br />95 General Plan Appendix A, p. 6-7. <br />96 Smith Comments p. 6. <br />97 General Plan p. 7-49. <br />98 General Plan p. 7-49. <br />112