SEACA, Public Counsel, CBC, and NRDC Comments on the CASP DEIR November 23, 2011 P. 36 of 78
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These mitigation measures must be incorporated in the Project, and if not incorporated, the revised and recirculated DEIR must explain why they are infeasible. In order to reduce impacts to the maximum extent feasible, the City must also require developers to comply with regulatory requirements, such as SCAQMD regulations, that are in effect at the time building permits are approved.
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In sum, no meaningful review of GHG impacts deficiencies described above in Parts 1 (improper baseline data) and 3 (omission of a projection of GHG emissions) of this section, in conjunction with its inadequate description regarding any mitigation measures. vi. The Draft EIR Should Utilize Additional LEED Tools to Mitigate Significant Environmental Impacts
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E. Transportation As described in the following sections, Chapter 4, Transportation of the DEIR is rife with technical and legal errors that must be corrected. i. The DEIR Uses an Improper Baseline for Analysis of Traffic Impacts
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The LOS analysis presented in the Transportation chapter of the DEIR rests on a faulty and illegal baseline that undermines the entire analysis of the chapter. The analysis erroneously compares the 2035 with-Project cumulative scenario to the 2035 cumulative No Action scenario, providing no analysis of with-Project conditions as compared to existing conditions. This omission is a violation of CEQA. A proper baseline is the starting point for proper CEQA An EIR must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the notice of preparation is published environmental setting will normally constitute the baseline physical conditions by which a lead (emphasis added)). EIR