Total Maximum Daily Loads

Total Maximum Daily Loads

Analyzing Cumulative Impacts Steven Blum 1 Requirements: Cumulative Impacts CEQA requires that we consider the impacts of the project in the context of all other projects in the area that might contribute to additive environmental impacts. Guidelines 15130 requires that a

cumulative impact analysis be included in an SED for a project with any significant impacts 2 What is a Cumulative Impact? Two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts. (a) The individual effects may be changes resulting from a single project or a number of separate projects. (b) The cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably

foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time. Guidelines 15355 3 Remember! Applies to all types of environmental impacts, not only water quality Applies to all projects that could have similar impacts, not only TMDLs or water-related projects

4 Cumulative Impact Analysis The cumulative impact analysis must identify: The cumulative incremental effect of the project A brief explanation of why each cumulative effect is or is not considered considerable or significant The discussion must reflect the severity of the impacts and their likelihood of occurrence 5

Cumulative Impact Analysis: Projects to Consider A list of past, present, and reasonably foreseeable future projects producing related or cumulative impacts Projects under consideration but not yet approved, for example, general plans or HCPs Projects for which applications have been submitted Project ideas under serious public discussion However, we are not required to speculate! (Guidelines 15145)

6 Cumulative Impacts Defining the Scope of the Analysis Define the geographic scope of the area affected by the cumulative effects Summarize the expected environmental effects to be produced by those projects Analyze the cumulative impacts of the related projects 8

What is NOT a Cumulative Impact? If your project would have NO Impact in a topic area it will not contribute to a cumulative impact to that resource area (Refer to responses on your checklist) Cumulative impacts adequately addressed in a prior environmental document, community plan, or State Board SED (Guidelines 15130(d)&(e))

A projects contribution is less than cumulatively considerable if its proponent is required to implement or fund its fair share of mitigation designed to alleviate the cumulative impact (Guidelines 15130(a)(3)) 9 How to Determine Significance of Cumulative Impacts 1. 2. Review other projects 3.

Determine the timing, location, and magnitude of the impacts 4. 5. Apply standard thresholds of significance Determine where there are or will be similar impacts Apply Fair Argument to determine significance If an impact is cumulatively considerable, treat it as significant in the SED

10 CEQA Requirements for Cumulative Impact Analysis Determine whether the project contributes to a significant cumulative impact Determine whether your contribution is considerable in cumulative context

Require mitigation to avoid contribution, if feasible Considerable contribution = significant effect Small ratio can be considerable Small contribution can be considerable 11 Scope of the Cumulative Impact Analysis Define the cumulative area of effect Might be beyond watershed depends upon context

Different impacts have different areas of effect CEQAs requirements: Plan or projections approach Adopted plan or projections that describe the cumulative impact List approach List of past, present, and reasonably foreseeable future projects 12

Speculation v. Forecasting CEQA does not require speculation If analysis would be speculative, explain why CEQA does require forecasting Reasonable, good-faith effort is sufficient Places to look: General plan or capital improvement plans Projects approved, but not built Applications on file 13

Questions? 14

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