SEACA, Public Counsel, CBC, and NRDC Comments on the CASP DEIR November 23, 2011 P. 50 of 78 27-101
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potential impact is less than significant. With respect to mitigation, the measures identified in this chapter are vague and unenforceable and give no assurances that the area will in fact be safe for planned uses. For example, Mitigation Measure Hazardous Materials 4 provides that sites currently listed on the Cortese List must either be remediated to the point that they are removed from the Cortese List, that the proposed uses include measures that would prevent any hazards to the public or the -18). Additionally, the locating of hazardous materials or waste within ¼ mile of a school is considered a significant impact (DEIR, p. 10-17). Yet the mitigation fails to acknowledge that, given DEIR Figure 11-1, over half of the CASP area is within ¼ mile of a school so there is a high likelihood that new uses would be within this proximity. This is especially critical when considering that the two Emergency Response Notification Sites from 2010 (of which there are 31 within the Project Area, (DEIR, p. 10-7)) occurred within this ¼ mile proximity. Although review and approval by the Los Angeles Fire Department and California Environmental Protection Agency will be required, this mitigation measure gives no indication of the types of measures that could be used, nor what constitutes compliance. As discussed further below, a specific performance standard and alternative means of achieving that standard should be set forth in the DEIR. In addition, an EIR violates CEQA where the EIR does not address the potentially significant impacts associated with implementation of mitigation measures. (See Gray v. County of Madera (2008) 167 Cal.App.4th 1099, 1118). It is unknown whether the hazards mitigation will require extensive excavation, capping, or hazardous materials transport through existing neighborhoods, remediation methods that themselves could have significant environmental impacts. In addition, as described in more detail below at Section II.M, the cumulative impacts analysis for hazardous materials completely ignores the potential impacts of dozens of site remediation projects being undertaken within the CASP area at the same time. As acknowledged b materials impacts, and remediation may be required for individual development projects as well as for infrastructure projects. (DEIR, p. 17-6). Yet the DEIR is silent as to the combined impacts of these remediation needs and projects. Even assuming that all projects adhere to state and local requirements, the combined impacts of, for example, multiple sites within the CASP simultaneously undergoing contaminated soil excavation and extraction or asbestos abatement, may together create significant impacts to the surrounding environment. G.
Visual Resources
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The visual resources analysis of the EIR fails to identify and analyze impacts to viewsheds, nighttime lighting and glare, and shadows. These omissions are violations of that the agency (Laurel Heights, supra, 47 Cal.3d at 392).
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The aesthetics impacts analysis [a]ll exterior lighting (building, landscape, and security) is to be integrated with building design without casting light into the night sky,