3.0 Responses to Comments
See response to comment 27-72. 27-145 The comment claims that the Original DEIR does not follow guidelines described in the City of Los Angeles CEQA Thresholds Guide, particularly in relation to cumulative projects and their impact to population. The comment highlights Table 17-1 (p. 17-3), which lists “related projects” (i.e. nearby projects, whose individual impacts combine with those of the Proposed Alternative to produce cumulative impacts), and takes issue with the absence of population figures listed therein. As explained in Original DEIR Section 17.2.2, CEQA Guidelines (section 15130) recommend using either a "list" or "projection" approach to identify these projects. The list approach requires the identification of all… projects that could contribute to a significant cumulative environmental impact. A projection approach requires a review of related planning documents that describe regional conditions related to the cumulative impact. This EIR uses a combination of these approaches. (p. 17-2)
The cumulative impacts of Population, Housing, and Employment are analyzed using the “projection” approach. In the same section, the Original DEIR further explains, Section 15130(b) of the Guidelines indicates that the level of detail of the cumulative analysis need not be as great as for the project impact analyses, that it should reflect the severity of the impacts and their likelihood of occurrence, and that it should be focused, practical, and reasonable. (p. 17-1)
See Response 27-31 for a discussion of the significance of population and housing impacts due to infill development, and its role in offsetting growth elsewhere in the region. 27-146 The comment expresses concern that the Original DEIR has not adequately analyzed the potential cumulative impacts given that the projects listed in Table 17-1 do not correspond to the area of concern for the different impacted resource categories citing Section 15130(b) of the CEQA Guidelines. As stated on page 17-2 of the Original DEIR, the cumulative impact analysis applied both a list approach and a projection approach in the cumulative evaluation. A projection based approach was undertaken with the analysis of impacts that are either more regional in nature, or would likely occur outside of the Project Area such as the following: transportation impacts (see discussion of Cumulative 2035 Conditions in Section 17.2.4 of the Original DEIR), and water supply impacts (See discussion on Water Demand Forecast in the Original DEIR Appendix 7B Water Supply Assessment). For certain impact areas, the cumulative impact methodology is already captured in the threshold such as greenhouse gas impacts (see Section 2.B of the RPDEIR) and regional air quality - criteria air pollutant emissions. However, for impacts that are more localized in nature, a list-based approach is more appropriate. The projects included in Table 17-1 were identified to determine if local projects could, in confluence with the Proposed Alternative, contribute to a significant impact. The projects that were identified were small in scale and would be constructed in a relatively short time frame, and therefore not shown to contribute to a potentially Cornfield Arroyo Seco Specific Plan FEIR
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