Comments on Draft Environmental Impact Report for Phillip Road Project (SCH No. 2025060240)

Document Date: April 30, 2026
Author: ADAMS BROADWELL JOSEPH & CARDOZO
Clark & Associates Environmental Consulting, Inc.; Wilson Ihrig, Acoustical Consultants
Summary: Formal CEQA objection letter asserting that the City cannot lawfully approve the Phillip Road Project until the Draft Environmental Impact Report (DEIR) is revised to provide a clearer project description, stronger impact analysis, additional mitigation, and recirculation for public review. Submitted by professional law firm Adams Broadwell Joseph & Cardozo on behalf of Placer County Residents for Responsible Development, this CEQA public comment letter (dated April 30, 2026) argues that the DEIR is legally and technically inadequate and should be revised and recirculated before the City approves the project. The proposed project involves approximately 241 acres at 6382 Phillip Road and includes up to 664 residential units, retail, medical office space, over 1 million square feet of “innovation center” uses, parks, open space, trails, infrastructure improvements, a new electrical substation, and a bridge connection across Pleasant Grove Creek. The comment letter’s central claim is that the DEIR fails as an informational document under CEQA because it allegedly understates, omits, or inadequately mitigates significant environmental impacts. Major issues raised include: 1) Incomplete project description, especially regarding the proposed data center. The letter argues the DEIR does not clearly disclose the size, capacity, or environmental implications of the data center, even though references suggest it could be approximately 40–45 MW. 2) Air quality and health-risk deficiencies. The attached expert comments by James Clark, Ph.D. argue that the DEIR’s health-risk analysis improperly omits passenger-vehicle emissions, including VOCs associated with toxic air contaminants, thereby underestimating operational and combined construction/operational health risks. 3) Battery Energy Storage System risks. The letter states that the DEIR fails to analyze potential hazards from the proposed BESS, including lithium-ion battery thermal runaway, fire, explosion, toxic gas release, and related air quality/public health risks. 4) Noise impacts. The attached noise expert, Jack Meighan, argues that construction noise is not adequately analyzed or mitigated, that operational traffic noise may have feasible mitigation such as rubberized asphalt, and that data-center cooling/HVAC noise could exceed applicable nighttime standards. 5) Energy analysis deficiencies. The letter argues the DEIR does not adequately analyze whether the project—particularly data-center uses—would result in wasteful, inefficient, or unnecessary energy consumption. 6) Biological resources. The letter claims the DEIR fails to adequately analyze and mitigate impacts to Blue Oak Woodland, which it identifies as a sensitive natural community. 7) Entitlement findings. The letter argues the City lacks substantial evidence to approve the General Plan Amendment, rezone, Major Project Permit, Development Agreement, and Tentative Parcel Map because the DEIR does not adequately address air quality, hazards, public health, energy, biological, and noise impacts. 8) Workforce standards. The letter separately recommends that the City ask the applicant to include workforce benefits, such as local hire and apprenticeship requirements, in the Development Agreement to improve consistency with General Plan economic-development policies.
Key Quote / Excerpt: Based on our review of the DEIR, it is clear that the DEIR fails as an informational document under CEQA and lacks substantial evidence to support its conclusions that the Project’s significant impacts would be mitigated to the greatest extent feasible.

Based on our review of the DEIR, it is clear that the DEIR fails as an informational document under CEQA and lacks substantial evidence to support its conclusions that the Project’s significant impacts would be mitigated to the greatest extent feasible.

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