From a CEQA impact-avoidance perspective, the most complete and reliable way to avoid the DEIR’s admitted “significant and unavoidable” impacts is the No Project Alternative: do not approve or build the proposed Phillip Road Project on the public parcel at 6382 Phillip Road, Roseville, California 95747 USA.
| Category | DEIR-Identified Significant and Unavoidable Impact | DEIR Citations | Why It Matters |
|---|---|---|---|
| Transportation / Pedestrian Facilities | Conflict with adopted policies, plans, or programs regarding pedestrian facilities. | DEIR Executive Summary, p. ES-4; Table ES-1, p. ES-8; Section 3.3, pp. 3.3-26 to 3.3-27; Chapter 5, p. 5-4. | The DEIR identifies a significant and unavoidable impact because continuous pedestrian facilities on Blue Oaks Boulevard adjacent to the site are not assured. Mitigation depends on obtaining rights from an adjacent property owner, and the City states it lacks jurisdiction to monitor or enforce that mitigation. |
| Transportation / Transit Facilities | Conflict with adopted policies, plans, or programs regarding transit facilities. | DEIR Executive Summary, p. ES-4; Table ES-1, p. ES-8; Section 3.3, p. 3.3-28; Chapter 5, pp. 5-4 to 5-5. | The site is not currently served by fixed-route transit. The DEIR states that fair-share funding would not guarantee actual transit service because remaining funding sources are unknown and the transit system enhancement is not a higher-priority near-term improvement. |
| Air Quality / Construction Emissions | Construction emissions. | DEIR Executive Summary, p. ES-4; Chapter 4, p. 4-16; Chapter 5, pp. 5-6 to 5-7. | Construction activity would contribute to cumulative air-quality degradation. The DEIR states that overlapping cumulative construction activities could result in emissions exceeding applicable daily construction thresholds, making the cumulative impact significant and unavoidable. |
| Air Quality / Operational Criteria Pollutants and Ozone Precursors | Long-term operational emissions of criteria air pollutants and ozone precursors. | DEIR Executive Summary, p. ES-4; Table ES-1, pp. ES-8 to ES-9; Section 3.4, pp. 3.4-23 to 3.4-28; Chapter 4, pp. 4-16 to 4-17; Chapter 5, pp. 5-5 to 5-7. | The project would generate ongoing operational emissions, including ozone precursors. The DEIR states that because future tenants are unknown and offset availability cannot be guaranteed when needed, the impact remains significant and unavoidable. |
| Air Quality / Toxic Air Contaminants | Toxic air contaminants. | DEIR Executive Summary, p. ES-4; Section 3.4, p. 3.4-28; Chapter 4, p. 4-17; Chapter 5, p. 5-8. | The DEIR identifies a significant and unavoidable cumulative toxic-air-contaminant impact because future combined TAC concentrations cannot be determined with certainty, including whether sensitive receptors could be exposed to risk levels above applicable thresholds when combined with other projects. |
| Greenhouse Gas Emissions / Climate Change | Generation of greenhouse gas emissions, directly or indirectly, that may have a significant impact on the environment. | DEIR Executive Summary, p. ES-4; Table ES-1, p. ES-9; Section 3.5, pp. 3.5-14 to 3.5-18; Chapter 4, p. 4-18; Chapter 5, pp. 5-5 to 5-8. | The DEIR indicates that future tenants are unknown and exact on-site greenhouse gas reductions cannot be quantified or guaranteed. As a result, the project’s contribution to cumulative greenhouse gas emissions remains significant and unavoidable. |
| Noise / Traffic Noise | Exposure of existing sensitive receptors to excessive traffic noise levels. | DEIR Executive Summary, p. ES-4; Table ES-1, p. ES-9; Section 3.6, pp. 3.6-17 to 3.6-19; Chapter 5, p. 5-8. | Project-generated traffic would expose existing sensitive receptors to excessive noise levels. The DEIR identifies a substantial traffic-noise increase on Blue Oaks Boulevard from the project site to Westbrook Boulevard and states that no additional feasible mitigation is available. |
| Utilities / Infrastructure Capacity | New or expanded utility infrastructure or determination of inadequate capacity. | DEIR Executive Summary, p. ES-4; Section 3.11, pp. 3.11-13 to 3.11-21; Chapter 4, p. 4-26; Chapter 5, p. 5-9. | The DEIR identifies significant and unavoidable cumulative utility impacts because recycled-water infrastructure improvements needed for full buildout have not yet been specifically located, designed, timed, or evaluated for construction methods, so the environmental impacts cannot be fully evaluated and feasible mitigation cannot be identified. |
| Aesthetics / Visual Character and Quality | Visual character and quality. | DEIR Executive Summary, p. ES-4; Chapter 4, p. 4-29; Chapter 5, pp. 5-9 to 5-10. | The DEIR identifies cumulative visual-character impacts as significant and unavoidable because the project would combine with other development to place urban uses next to agricultural, grazing, and open-space areas, substantially degrading visual quality. |
| Aesthetics / Light and Glare | Light and glare. | DEIR Executive Summary, p. ES-4; Chapter 4, pp. 4-29 to 4-30; Chapter 5, p. 5-10. | The DEIR identifies cumulative light and glare impacts as significant and unavoidable because the project would combine with other development to increase daytime glare and nighttime lighting in areas that currently have more scattered and dispersed light sources. |
“Unknown unknowns” and why No Project is the cleanest avoidance alternative
The proposed Phillip Road Project has admitted unavoidable impacts plus uncertainty about the real operational intensity of the proposed innovation/data-center uses.
Key uncertainty points include:
- Unknown future tenants. The DEIR acknowledges actual tenants are not known, and uses that uncertainty in the GHG analysis to state that exact on-site GHG reductions cannot be quantified or guaranteed.
- Potential data center scale. The Adams Broadwell letter states the DEIR fails to adequately describe the proposed data center, including size and scale, and notes record references suggesting a potential 40–45 MW data center.
- Battery Energy Storage System risk. The comment letter argues the DEIR fails to disclose, analyze, and mitigate BESS risks, including lithium-ion thermal runaway, fire, explosion, toxic gas release, air-quality impacts, public-health risks, and fire hazards.
- Infrastructure sizing and regional growth-inducement questions. A separate public comment letter argues the infrastructure is sized/configured for a regional freight corridor and large-scale data-center facility, including a 60-inch sewer trunk line, high-voltage substation, large backup generation capacity, recycled-water cooling demand, and Placer Parkway / STAA freight-alignment issues.
- Placer Parkway / interchange reservation. The comment letter argues the 22.7-acre reservation is a project characteristic, not merely an external cumulative condition, and that siting the innovation center at a future regional expressway interchange has not been adequately analyzed as a project-specific freight/air-quality/traffic feature.
From a risk-avoidance standpoint, not approving the project avoids both the admitted known residual impacts and the unresolved “unknown unknowns” associated with future tenant mix, data-center intensity, backup generation, BESS hazards, cooling demand, freight routing, and infrastructure growth inducement.
Stop Phillip Road Site Rezoning That Could Allow an AI Data Center
Roseville residents are concerned about increased noise, traffic, environmental impacts, water quality and supply, infrastructure strain, and the loss of land currently designated for public and community-serving purposes.