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November 8, 2024 Page 6 7357-013acp printed on recycled paper environment” and “to list ways in which the significant effects of such a project might be minimized.”22 The use of inaccurate and flawed information on which the DEIR bases its conclusions results in underestimated Project impacts. This, in turn, leads to a failure to comply with CEQA’s requirement that an agency mitigate “all significant environmental impacts to the greatest extent feasible, and that any remaining significant environmental impacts are acceptable due to overriding considerations.”23 Mitigation of impacts to the fullest extent feasible requires an agency to accurately quantify the severity of Project impacts. Because the DEIR’s analyses underestimate the severity of the Project’s impacts, the County has failed to comply with CEQA and thus cannot approve the Project based upon the DEIR’s unsupported analyses and conclusions. CEQA requires recirculation of a DEIR for public review and comment when significant new information must be added to the DEIR following public review, but before certification.24 The CEQA Guidelines clarify that new information is significant if “the DEIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the Project or a feasible way to mitigate or avoid such an effect.”25 The purpose of recirculation is to give the public and other agencies an opportunity to evaluate the new data and the validity of conclusions drawn from it.26 Here, the DEIR must be revised and recirculated to include analysis of impacts associated with the adjacent Senior East County Lakes Project.27 The additional information required to analyze the concurrent and cumulative impacts of the two projects on the same assessor parcel, by the same developer, will result in the addition of significant new information to the EIR, necessitating recirculation pursuant to Public Resources Code Section 21092.1. For the reasons detailed herein and in the expert consultant reports attached hereto, the DEIR must be revised to resolve its inadequacies and recirculated for public review and comment. III. THE DEIR’S PROJECT DESCRIPTION IS INADEQUATE The DEIR does not meet CEQA’s requirements because it fails to include an accurate and complete Project description, rendering the entire analysis inadequate. 22 Laurel Heights I, supra, 47 Cal.3d at p. 391. 23 CEQA Guidelines, §§ 15090, 15091. 24 Pub. Resources Code § 21092.1. 25 14 Cal. Code Regs. § 15088.5. 26 Save Our Peninsula Comm. v. Monterey City Bd. of Supervisors (1981) 122 CalApp3d 813, 822. 27 Arviv Enters., Inc. v. South Area Planning Comm’n (2002) 101 CA4th 1333,