SEACA, Public Counsel, CBC, and NRDC Comments on the CASP DEIR November 23, 2011 P. 62 of 78
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problem is so severe, even a seemingly minor incremental change is cumulatively considerable.
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As discussed with regards to traffic, noise and visual resources, the DEIR has sought to subsume -degraded conditions. The cumulative impacts analysis carries forward this flawed reasoning, and fails to address the cumulative changes that will be wrought on the community by the CASP and surrounding projects.
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The misapplication of the traffic and transportation baseline the comparison of projected 2035 conditions with the Project to a 2035 No Project scenario rather than a comparison to existing conditions is repeated here in the cumulative impacts analysis. (DEIR, p. 17-4 to 17-5 [ [T]he Proposed Alternative would generate approximately 2,506,000 vehicle miles travelled (VMT) per day, an increase of approximately 159,000 VMT when compared to the cumulative ]). As discussed above, this analysis does not explain how 2035 with-Project conditions relate to existing conditions, in clear violation of CEQA. (Sunnyvale, supra, 190 Cal. App. 4th at 1380-1383). The Population, Housing and Employment section of the cumulative analysis also fails to meet the basic requirements of the City of Los Angeles CEQA Thresholds Guide.102 That guidance, at p. J.1-4 to J.1-5, explains that an EIR should: Determine the increase in housing units, occupancy and population associated with the related projects in the same manner as described above under Project Impacts. Compare the combined effect of the growth from the project and the related projects to the amount, timing and location of growth forecast for the project site and surrounding area in the adopted. If the area is currently underdeveloped or the project introduces new major infrastructure, also note whether the project or related projects would introduce infrastructure or accelerate development.
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Although Table 17-1 lists the square footage and number of parking spaces associated with the cumulative projects, it makes no estimates regarding population. (DEIR, p. 17-3). The text discussion of Population, Housing and Employment cumulative impacts does not even mention cumulative projects, discussing only the growth-inducing impacts of the CASP itself. (See DEIR, p. 17-6 to 17-7). iii.
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The Cumulative Project List Is Underinclusive
In evaluating cumulative impacts, an EIR may use a list approach, a projections approach, or a hybrid The discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence . . . and should focus on the cumulative impact to 102
Available at http://www.ci.la.ca.us/ead/programs/Thresholds/J-Population%20and%20Housing.pdf