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I the issuance of the negative declaration and use permit in a manner complying with law; 2 b. The filing and adoption of the initial study was improper as it can be fairly 3 argued from the evidence available that the slaughter house as permitted might have a 4 significant environmental impact. The initial study further fails to contain and address all 5 phases of project's planning, implementation, and operation, fails to reflect proper and 6 necessary investigation as to the potential of significant environmental impacts, improperly 7 fails to identify the environmental effects of the project in that it incorrectly answers "no" to a 8 number of questions when substantial evidence was available to the respondents compelling a 9 "yes" answer which, if given, would have necessitated environmental review at an early stage 10 by the preparation of an environmental impact report, and further relies on future permitting 11 and studies to address significant environmental impacts which the project may have, whether 12 or not ground water quality may be affected, whether or not the project is likely to increase 13 odors and whether the project has the potential to degrade the environment or cause adverse 14 effects on human beings. 15 C. Respondents improperly approved a negative declaration contrary to the 16 substantial evidence which demonstrated that the project would or might have a significant 17 environmental effect, based on the improper and inadequate initial study and failed to require 18 appropriate and effective potential mitigation measures. 19 13. The petitioners are a members of the public who has a vested interest in the 20 environmental quality of real property in and around the subject project. Petitioner, Leon 21 Lyon, Trustee of the William Harwell Lyon 1976 Trust further received no notice of any kind 22 of the hearing. Petitioner Citizens Against Slaughter House is an association including 23 members of the public who objected to the actions of respondents. 24 14. Petitioner has no plain, speedy or adequate remedy at law in that if real parties 25 in interest are allowed to go forward with the slaughter house and unless the request for 26 mandatory and injunctive relief is granted, petitioner will be irreparably be harmed, for which 27 harmed money and other legal remedies cannot adequately compensate them. 28 15. Petitioner has complied with Public Resources Code 21167.7 and Civil Code of a