CC RES 2021-062 RESOLUTION NO. 2021-62
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
RANCHO PALOS VERDES ADOPTING ADDENDUM
NO. 49 TO ENVIRONMENTAL IMPACT REPORT NO. 36 IN
CONNECTION WITH REVISION "HHH" TO THE TRUMP
NATIONAL GOLF CLUB PROJECT
WHEREAS, an application package was filed by the Zuckerman Building Company
and Palos Verdes Land Holdings Company requesting approval of tentative parcel maps,
vesting tentative tract maps, conditional use permits, a coastal permit and a grading
permit to allow the construction of a Residential Planned Development (RPD) of 120
single family dwelling units and for development of an 18-hole golf course, a clubhouse,
and parking facilities on a 258 acre site bounded by Palos Verdes Drive South on the
north, Portuguese Bend Club and Community Association on the west, the Pacific Ocean
on the south and Los Angeles County Shoreline Park on the east; and,
WHEREAS, a Draft Environmental Impact Report (DEIR) was prepared and
circulated for 45 days from June 7, 1991, through July 22, 1991, in order to receive written
comments on the adequacy of the document from responsible agencies and the public;
and,
WHEREAS, subsequent,to the circulation of the DEIR and preparation of written
responses, the applicant revised the scope of the project and reduced the number of
proposed single family residences to 40 units in Vesting Tentative Tract Map (VTTM) No.
50666 and 43 in VTTM No. 50667, and an 18 hole-golf course with related facilities within
the boundaries of both VTTMs, and, due to the changes in the project, an Addendum to
the DEIR was prepared; and,
WHEREAS, based on review of the Addendum to the DEIR, the City determined
that the information submitted cited potential additional significant environmental impacts
that would be caused by the revised project, and directed preparation of a Supplemental
Environmental Impact Report (SEIR). The SEIR, which incorporates information and
findings set forth in the Addendum to the DEIR, was prepared and circulated for 45 days
from March 19, 1992, through May 4, 1992, during which time all interested parties were
notified of the circulation period and invited to present written comments to the information
contained in the SEIR, in conformance with the requirements of the California
Environmental Quality Act (CEQA); and,
WHEREAS, on June 1, 1992, the City Council adopted Resolution No. 92-53
certifying Environmental Impact Report (EIR) No. 36, in connection with VTTM Nos.
50666 and 50667, Tentative Parcel Map Nos. 20970 and 23004, Conditional Use Permit
Nos. 162 and 163, Coastal Permit No. 103, and Grading Permit No. 1541 for an 83 lot
RPD, publicopen space, and an 18-hole public golf course with clubhouse and related
p
facilities on 261.4 acres in Coastal Subregions 7 and 8; and,
WHEREAS, on December 7, 1992, the City Council adopted Resolution
No. 92-115 approving Addendum No. 1 to ER No. 36, in connection with approving
revisions to the Trump National Golf Club project(formally known as Ocean Trails project)
applications described above, in order to address concerns expressed by the California
Coastal Commission (CCC) with regard to adequate provisions for public open space,
public access and habitat preservation; and,
WHEREAS, on October 5, 1993, the City Council adopted Resolution No. 93-89
approving Addendum No. 2 to EIR No. 36, in connection with re-approval of the Trump
National Golf Club project applications described above, in order to comply with a Court
mandate to provide affordable housing in conjunction with the project, pursuant to
Government Code Section 65590; and,
WHEREAS, on September 6, 1994, the City Council adopted Resolution
No. 94-71 approving Addendum No. 3 to EIR No. 36, in connection with approval of
Revision "A" to the Trump National Golf Club project applications described above, in
order to incorporate changes to the project made by the CCC in April 1993, and (based
on additional geologic information) relocate the golf course clubhouse, reduce the number
of single family lots from 83 to 75 and approve a location for the golf course maintenance
facility and on-site affordable housing units; and,
WHEREAS, on March 11, 1996, the City Council adopted Resolution No. 96-15
approving Addendum No. 4 to EIR No. 36, in connection with approval of Revision "B" to
the Trump National Golf Club project applications described above, in order to incorporate
changes to the project made by the CCC in January 1995 regarding the relocation of the
golf course clubhouse, Paseo Del Mar roadway and public trails to accommodate a
reconfiguration of the public parking facilities, as well as additional modifications to the
public trails in order to provide clarification or to be consistent with the CCC's approval
and to include an 8.5 acre vacant property owned by the Palos Verdes Peninsula Unified
School District into the golf course.
WHEREAS, on September 3, 1996, the City Council adopted Resolution No. 96-
72 approving Addendum No. 5 to EIR No. 36, in connection with approval of Revision "C"
to the Trump National Golf Club project applications described above, in order to relocate
two single family residential lots in VTTM No. 50667 from the end of Street "A" to the end
of Street "C," revise the boundaries of open space lots B, C, G and H, convert the split-
level lots in VTTM No. 50667 to single-level lots, revise the golf course layout, revise the
public trail system, combine parallel trail easements, construct a paved fire access road
west of the Ocean Terraces Condominiums and modify several amendments to the
conditions of approval and mitigation measures to change the required timing for
compliance; and,
WHEREAS, on August 18, 1998, the City Council adopted Resolution No. 98-76
approving Addendum No. 6 to EIR No. 36 and the proposed Revision "G" to the Trump
National Golf Club project, which included: 1) an 18% increase in the size of the
clubhouse from 27,000 square feet to 32,927 square feet; 2) an increase in the size of
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the maintenance facility from 6,000 square feet to 9,504 square feet; 3) a 2-foot increase
in the upslope height of the maintenance facility building; and, 4) relocation of the
maintenance building and reconfiguration of the maintenance facility parking lot.
WHEREAS, on February 2, 1999, the City Council adopted Resolution No. 99-10
approving Addendum No. 7 to EIR No. 36 and the proposed Revision "H" to the Trump
National Golf Club project, which included: changing six of the residential lots within
VTTM No. 50667 from flat pad lots to split level lots, lowering the overall pad elevation for
each lot, and lowering Street'B' within the subdivision, and lowering the pad elevation for
six other lots within the subdivision. Additionally, the approval included the modification
of the project's mitigation measures and conditions of approval to allow the permitted
construction hours for the entire Trump National Golf Club project to be expanded to
include Sundays through March 21, 1999.
WHEREAS, on May 4, 1999, the City Council adopted Resolution No. 99-29
approving Addendum No. 8 to EIR No. 35 and the proposed Revision "I" to the Trump
National Golf Club project, which included a change to the design of the storm drain
facilities of the Ocean Trails project from a tunneled pipe system to the existing on-site
canyons. Revision "I" only amended the drainage for the east side of the Trump National
Golf Club project, involving La Rotonda Canyon; and,
WHEREAS, on July 20, 1999, the City Council adopted Resolution No. 99-55
approving Addendum No. 9 to EIR No. 36 and the proposed Revision "J" to the Trump
National Golf Club project, which included: 1) the conditions requiring the establishment
of a maintenance district be revised by eliminating the maintenance district and having
the golf course owner be the sole responsible entity for maintenance, thereby excluding
the future residential homeowners; 2) withdrawn by applicant; 3) the timing of the
installation of ornamental fencing on each residential lot be delayed until prior to issuance
of certificate of occupancy; 4) delay the construction of two trails within VTTM No. 50666
from the Second Stage to the Third Stage of phasing within the Public Amenities Plan; 5)
lower the approved residential building pad elevations and create split-level pads in VTTM
No. 50666; 6) delay the payment of traffic impact fees to prior to Final Map No. 50666; 7)
allow an increase in total building area of the clubhouse by permitting a basement space;
8) withdrawn by applicant; and 9) revise the hours permitted for golf course landscape
gardening; and,
WHEREAS, on May 16, 2000, the City Council adopted Resolution No. 2000-27
approving Addendum No. 10 to EIR No. 36 and the proposed Revision "K" to the Trump
National Golf Club project, which allowed a portion of the golf course to open for play
before all of the required public amenities have been completed due to delays caused by
the failure of Landslide C on June 2, 1999; and,
WHEREAS, on June 21, 2000, the City Council adopted Resolution No. 2000-38
certifying a Final Supplemental EIR to EIR No. 36, adopting a Mitigation Monitoring
Program, adopting a Statement of Overriding Considerations, and the proposed Revision
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"L"to the Trump National Golf Club project, for the repair of Landslide C at Trump National
Golf Club; and,
WHEREAS, on July 18, 2000, the City Council approved Revision "M" to the
Trump National Golf Club project, thereby approving an amendment to the Habitat
Conservation Plan (HCP), an amendment to the HCP Implementing Agreement, and
approval of a Conservation Easement over the lower portion of Shoreline Park; and,
WHEREAS, on September 5, 2000, the City Council approved Revision "N"to the
Trump National Golf Club project, thereby approving a Mitigated Negative Declaration
and amending the project to accommodate a change to the design of the storm drain
facilities of the Ocean Trails project from a tunneled pipe system to the existing on-site
canyons. Revision "N" only amended the drainage for the west side of the Trump National
Golf Club project, involving Forrestal Canyon; and,
WHEREAS, on February 20, 2001, the City Council approved Revision "P" to the
Trump National Golf Club project, thereby approving an amendment to allow Trump
National Golf Club an extension of time to provide 4 on-site affordable housing units for
rent from "prior to one year of the opening of the clubhouse" to "prior to the opening of
the 18-hole golf course"; and,
WHEREAS, on February 20, 2001, the City Council approved Revision "Q" to the
Trump National Golf Club project, thereby approving an amendment which allows Ocean
Trails to re-construct (instead of re-pave) La Rotonda Drive from Palos Verdes South to
the end of La Rotonda Drive, in lieu of re-paving Palos Verdes Drive South from La
Rotonda Drive to the eastern City limits; and,
WHEREAS, on September 21, 2001, the City Council approved Revision "R" to
the Trump National Golf Club project to revise the conditions of approval for VTTM
No. 50666 and VTTM No. 50667, so as to adjust Condition 1-3 allowing an extension to
completing the reconstruction of La Rotonda Drive from Palos Verdes Drive South to its
end; and,
WHEREAS, on March 4, 2003, the City Council approved Amendment No. 2 to the
Ocean Trails Development Agreement to clarify that the City Council may extend any
approved tentative tract not to exceed the term of the Development Agreement and
extend VTTM No. 50666; and,
WHEREAS, on April 20, 2004, the City Council approved Revision "V"to the Trump
National Golf Club project to revise CUP No. 162, thereby allowing 1) basement areas of
one-story structures to be excluded from the existing 30% "Maximum Habitable Space"
requirement, but require that the basement habitable area be added to the first floor
habitable area in complying with the "Maximum Habitable Space Square Footage"
requirement; 2) permitting a change in the height of Lot No. 2 to allow for a subterranean
garage; and 3) permitted construction of retaining walls and access to the proposed
subterranean garage; and,
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WHEREAS, on October 4, 2005, the City Council approved Revision "X" to the
Trump National Golf Club project to revise CUP No. 162 so as to 1) allow a change in the
maximum habitable area for lots 26-29 in Tract No. 50667; 2) allow a change in the
maximum building height for lots no. 24-29 in Tract No. 50667, which includes allowing
lots 24 and 25 to have partially subterranean garages; 3) allow lots 24, 25 and 29 in Tract
No. 50667 to grade and construct improvements over existing 2:1 slopes; 4) allow up to
30% of the front and rear facades of all two-story and split level structures to have a full
two story façade without being broken by an architectural feature; and 5) to decrease the
lot area of Lot D, within VTTM No. 50666 from 1.4 acres to 1.0 acres; and,
WHEREAS, on November 20, 2007, the City Council approved Amendment No. 3
to the Ocean Trails Development Agreement which extended the life of the Development
Agreement and existing VTTM No. 50666 from November 20, 2007, through March 9,
2008; and,
WHEREAS, on March 4, 2008, the City Council approved Amendment No. 4 to the
Ocean Trails Development Agreement which extended the life of the Development
Agreement and existing VTTM No. 50666 from March 9, 2008, through July 18, 2008;
and,
WHEREAS, on July 15, 2008,, the City Council approved Amendment No. 5 to the
Ocean Trails Development Agreement which extended the life of the Development
Agreement and existing VTTM No. 50666 from July 18, 2008, through October 22, 2008;
and,
WHEREAS, on October 21, 2008, the City Council approved Amendment No. 6 to
the Ocean Trails Development Agreement which extended the life of the Development
Agreement and existing VTTM No. 50666 from October 22, 2008, through January 22,
2008; and,
WHEREAS, on January 21, 2009, the City Council approved Revision "RR" to the
Trump National Golf Club project, which extended the life of the Development Agreement
and existing \TTM No. 50666 from January 22, 2009, through July 22, 2009, and revised
Grading Permit No. 1541 to allow an additional temporary opening of the driving range to
the public through July 22, 2009; and,
WHEREAS, on July 21, 2009, the City Council, via Minute Order, approved a two-
month extension (Revision "SS") of the Development Agreement, VTTM No. 50666 and
the temporary use of the driving range at the request of the Applicant in order to
accommodate the Applicant's schedule and availability to attend the Council meeting.
Said two-month extension was granted to September 16, 2009. As part of that action, the
Council also continued the item/public hearing on Revision "SS" to September 15, 2009;
and
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WHEREAS, on September 15, 2009, the City Council approved Revision "SS" to
the Trump National Golf Club project, which extended the life of the Development
Agreement and existing VTTM No. 50666 from September 16, 2009, through March 17,
2010, and revised Grading Permit No. 1541 to allow an additional temporary opening of
the driving range to the public through March 17, 2010; and,
WHEREAS, on March 16, 2010, the City Council approved Revision "UU" to the
Trump National Golf Club project, which extended the life of the Development Agreement
and existing VTTM No. 50666 from March 16, 2010, through September 21, 2010, and
revised Grading Permit No. 1541 to allow an additional temporary opening of the driving
range to the public through September 21, 2010; and,
WHEREAS, on September 21, 2010, the City Council approved Revision "VV" to
the Trump National Golf Club project, which extended the life of the Development
Agreement and existing VTTM No. 50666 from September 21, 2010, through March 21,
2011, and revised Grading Permit No. 1541 to allow an additional temporary opening of
the driving range to the public through March 21, 2011; and,
WHEREAS, on March 15, 2011, the City Council approved Revision "WW' to the
Trump National Golf Club project, which extended the life of the Development Agreement
and existing VTTM No. 50666 from March 21, 2011, through September 21, 2011, and
revised Grading Permit No. 1541 to allow an additional temporary opening of the driving
range to the public through September 21, 2011; and,
WHEREAS, on September 20, 2011, the City Council approved Revision "XX" to
the Trump National Golf Club project, which extended the life of the Development
Agreement and existing VTTM No. 50666 from September 21, 2011, through March 21,
2012, and revised Grading Permit No. 1541 to allow an additional temporary opening of
the driving range to the public through September 21, 2012; and,
WHEREAS, on March 6, 2012, the City Council approved Revision "AAA" to the
Trump National Golf Club project, which extended the life of the Development Agreement
and existing VTTM No. 50666 from March 21, 2012, through September 21, 2012, and
revised Grading Permit No. 1541 to allow an additional temporary opening of the driving
range to the public through September 21, 2012; and,
WHEREAS, on August 7, 2012, the City Council approved Revision "BBB" to the
Trump National Golf Club project, which extended the life of the Development Agreement
and existing VTTM No. 50666 from September 21, 2012, through September 21, 2014,
and revised Grading Permit No. 1541 to allow an additional temporary opening of the
driving range to the public through September 21, 2014; and,
WHEREAS, on September 16, 2014, the City Council approved Revision "DDD"
to the Trump National Golf Club project, which extended the life of the Development
Agreement and existing VTTM No. 50666 from September 21, 2014, through September
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21, 2016, and revised Grading Permit No. 1541 to allow an additional temporary opening
of the driving range to the public through September 21, 2016; and,
WHEREAS, on August 16, 2016, the City Council adopted Resolution
No. 2016-36, approving Addendum No. 47 to EIR No. 36; adopted Urgency Ordinance
No. 587U, authorizing an extension to the Development Agreement to September 21,
2018; extended VTTM No. 50666 consistent with the term of the Development
Agreement; and adopted Resolution Nos. 2016-37 and 2016-38, approving Revision
"EEE" to Grading Permit No. 1541 to allow an extension to the operation of the driving
range to the public through September 21, 2018; and,
WHEREAS, on June 19, 2018, the City Council adopted Resolution No. 2018-39,
approving Revision "FFF"to Conditional Use Permit No.162 to amend Condition No. F1.0
(Resolution No. 2008-85) to remove the requirement to build a solid 5-foot to 6-foot tall
wall along the west property line adjacent to the properties in the Portuguese Bend Club;
consolidate the various conditions of approval tied to the Trump National Golf Club
project; and update the 1997 Public Amenities Map; and,
WHEREAS, on September 21, 2021, the City Council adopted Resolution No.
2021-47, approving Addendum No. 48 to the Mitigated Negative Declaration, and adopted
Resolution No. 2021-48 approving Revision "GGG" to allow Lot No. 11 to be constructed
at 16 feet from pad of the one-story structure, and 26 feet from the entry to a subterranean
garage and exterior basement patio areas, with a ridge height that does not exceed 16
feet above the existing pad elevation; and,
WHEREAS, on August 31, 2021, Michael Mulligan (Applicant) submitted an
application to the City of Rancho Palos Verdes requesting approval of Revision "HHH" to
allow Lot No. 9 to be constructed at 16 feet from pad of the one-story structure, and
26 feet from the entry to a subterranean garage and exterior basement patio areas,
provided that the ridge height does not exceed 16 feet above the existing pad elevation;
and,
WHEREAS, pursuant to the provisions of the California Environmental Quality Act,
Public Resources Code Sections 21000 et. seq. ("CEQA"), the State CEQA Guidelines,
California Code of Regulations, Title 14, Sections 15000 et. seq., the City's Local CEQA
Guidelines, and Government Code Section 65952.5(e) (Hazardous Waste and
Substances Statement), on November 9, 2021, copies of the draft Addendum No. 49 to
EIR No. 36 were, distributed to the City Council in its City Council agenda packet and on
November 16, 2021, prior to taking action on the proposed Revision "HHH" to the Trump
National Golf Club project, the City Council independently reviewed and considered the
information and findings contained in Addendum No. 49 to EIR No. 36; and,
WHEREAS, on November 16, 2021, after notice issued pursuant to the provisions
II of the Zoning Code, the City Council held a public hearing to consider draft Addendum
No. 49 to EIR No. 36 and the proposed Revision "HHH" to the Trump National Golf Club
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project, at which time all interested parties were given an opportunity to be heard and
present evidence. I
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF RANCHO PALOS
VERDES DOES HEREBY FIND, DETERMINE, AND RESOLVE AS FOLLOWS:
Section 1: Revision "HHH" to the Trump National Golf Club project is to allow a
change in the maximum building height for Lot No. 9 of Tract No. 50667. Pursuant to
Sections 15162 and 15164 of the State CEQA Guidelines, approval of Addendum No. 49
to the previously certified EIR No. 36, rather than the preparation of a subsequent or
supplemental EIR, is appropriate for the consideration of the proposed revision to the
Trump National Golf Club project, based on the following findings:
1. That subsequent changes proposed to the project do not require important
revisions to the previous EIR, since there are no new significant environmental
impacts that have been identified, which were not considered in the previous EIR.
This is so since the proposed changes identified in Section 1 and attached Exhibit
"A" would not result in any new or increased impacts to the environment that are
not already analyzed within EIR No. 36. Specifically, Revision "HHH"will not result
in adverse impacts to 1) views from neighboring properties nor the public right-of-
way in the vicinity as the proposed subterranean features will not be readily visible,
2) parking or traffic related matters, and 3) geology. Furthermore, there have been
no substantial changes to the project or to the environment that would cause the
project to significantly impact the environment, nor does the proposed amendment
affect a change that would impact the environment in any manner that was not
previously considered and mitigated to the extent feasible.
2. That substantial changes to the project would not occur with respect to the
circumstances under which the project is undertaken, which would require
important revisions to the previous EIR, since, as noted above, there are no new
significant environmental impacts that were not considered in the previous EIR,
Supplement and previous Addenda thereto, and the project is limited to changes
that will not be readily visible from neighboring properties nor the public right-of-
way in the vicinity.
3. That there is no new information of substantial importance to the project which
indicates that these proposed changes will have one or more significant effects not
discussed previously in the EIR; that significant effects previously examined will
not be substantially more severe than shown in the EIR; that no mitigation
measures or alternatives, previously found not to be feasible, would now in fact be
feasible and would substantially reduce one or more significant effects of the
project; or that no mitigation measures or alternatives which were not previously
considered in the EIR, would now substantially lessen one or more significant
effects of the environment, because this project is only to allow modifications that
would not be readily visible to neighboring properties or from the public right-of-
way.
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Section 2: In approving Addendum No. 49 to EIR No. 36, the City Council has
reviewed and considered the Addendum No. 49 document, attached hereto and made a
part thereof as Exhibit "A."
Section 3: The Addendum No. 49 to EIR No. 36 identifies no new potential
significant adverse environmental impacts to the areas listed below, beyond those already
identified in the Final EIR No. 36, the Supplement, Second Supplement, and Addenda
Nos. 1 through 49 to EIR No. 36, as a result of the proposed revisions, to the Trump
National Golf Club project:
1. Landform, Geology, and Soils
2. Hydrology and Drainage
3. Biological Resources
4. Cultural and Scientific Resources
5. Aesthetics
6. Land Use and Relevant Planning
7. Circulation and Traffic
8. Air Resources
9. Noise
10. Public Services and Utilities
11. Population, Employment and Housing
12. Fiscal Impacts
Section 4: That implementation of the proposed changes to the project would not
require additional mitigation measures or significant deletions/modifications to the
mitigation measures included in the Final EIR, as well as the Supplemental, Second
Supplemental, and Addenda Nos. 1 through 49 to EIR No. 36.
Section 5: While the implementation of mitigation measures as discussed in the
Final EIR No. 36 and the Supplemental, and the Second Supplemental, and Addenda
EIR Nos. 1 through 49 to EIR No. 36 will further reduce these impacts, it is not possible
to entirely eliminate cumulative impacts to the areas of concern listed in Section 1, above.
Therefore, the Findings and Statement of Overriding Considerations, as provided in Final
EIR No. 36, are hereby incorporated by reference.
Section 6: All findings, attachments and Statement of Overriding Considerations
contained in Resolution Nos. 92-53, 92-115, 93-89, 94-71 and 96-15, as adopted by the
City Council on June 1, 1992, December 7, 1992, October 5, 1993, September 6, 1994,
March 11, 1996, and September 3, 1996, respectively, are hereby incorporated by
reference.
Section 7: The time within which the judicial review of the decision reflected in this
Resolution, if available, must be sought is governed by Section 1094.6 of the California
Code of Civil Procedure or any other applicable short period of limitations.
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Page 9 of 10
Section 8: For the foregoing reasons and based on the information and findings
contained in the staff reports, minutes, and evidence presented at the public hearings,
the City Council hereby approves Addendum No. 49 to EIR No. 36, based on the City
Council's determination that the document was completed in compliance with the
requirements of CEQA and State and local guidelines with respect thereto.
PASSED,, APPROVED, and ADOPTED this 16th day of November 2021.
°4EkiiiV
•
Eric �Ale ria Mayo 1
g
Attest:
er- .-Takaoka, City Clerk
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES )ss
CITY OF RANCHO PALOS VERDES )
I, Teresa Takaoka, City Clerk of the City of Rancho Palos Verdes, do hereby certify that
the above Resolution No. 2021-62, was duly adopted by the City Council of said City at
a regular meeting thereof held on November 16, 2021.
eres kaoka, City Clerk
111
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Resolution No. 2021-62
Exhibit "A"
ADDENDUM NO. 49
TO
ENVIRONMENTAL IMPACT REPORT NO. 36
The City Council has reviewed the proposed Revision "HHH" to the Trump National Golf
Club project, which is a request to allow a change in the maximum building height for Lot
No. 9 of Tract No. 50667 to accommodate a subterranean garage and exterior basement
patio area, in conjunction with the requirements of the California Environmental Quality
Act (CEQA), as well as State and Local CEQA Guidelines, and find as follows:
That the approved request would not result in any new or increased impacts to the
environment that are not already analyzed within EIR No. 36, because no significant
impacts will result from the approved changes. Specifically, Revision "HHH" will not result
in adverse impacts to 1) views from neighboring properties nor the public right-of-way in
the vicinity as the proposed subterranean features will not be readily visible, 2) parking or
traffic related matters, and 3) geology. Furthermore, there have been no substantial
changes to the project or to the environment that would cause the project to significantly
impact the environment, nor does the proposed amendment affect a change that would
impact the environment in any manner that was not previously considered and mitigated
to the extent feasible.
I
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