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Local Guidelines for Implementing the <br />California Environmental Quality Act (2023) INITIAL STUDY <br /> <br /> <br />2023 City of Santa Ana Local Guidelines 5-5 ©Best Best & Krieger LLP <br />answers were checked. If practicable, attach a list of reference materials, such as prior EIRs, plans, <br />traffic studies, air quality data, or other supporting studies. <br />5.08 EVALUATING SIGNIFICANT ENVIRONMENTAL EFFECTS. <br />In evaluating the environmental significance of effects disclosed by the Initial Study, the <br />Lead Agency shall consider: <br />(a) Whether the Initial Study and/or any comments received informally during consultations <br />indicate that a fair argument can be made that the project may have a significant adverse <br />environmental impact that cannot be mitigated to a level of insignificance. Even if a fair <br />argument can be made to the contrary, an EIR should be prepared; <br />(b) Whether both primary (direct) and reasonably foreseeable secondary (indirect) <br />consequences of the project were evaluated. Primary consequences are immediately <br />related to the project, while secondary consequences are related more to the primary <br />consequences than to the project itself. For example, secondary impacts upon the resources <br />base, including land, air, water and energy use of an area, may result from population <br />growth, a primary impact; <br />(c) Whether adverse social and economic changes will result from a physical change caused <br />by the project. Adverse economic and social changes resulting from a project are not, in <br />themselves, significant environmental effects. However, if such adverse changes cause <br />physical changes in the environment, those consequences may be used as the basis for <br />finding that the physical change is significant; <br />(d) Whether there is serious public controversy or disagreement among experts over the <br />environmental effects of the project. However, the existence of public controversy or <br />disagreement among experts does not, without more, require preparation of an EIR in the <br />absence of substantial evidence of significant effects; <br />(e) Whether the cumulative impact of the project is significant and whether the incremental <br />effects of the project are “cumulatively considerable” (as defined in Local Guidelines <br />Section 11.14) when viewed in connection with the effects of past projects, current <br />projects, and probable future projects. The City may conclude that a project’s incremental <br />contribution to a cumulative effect is not cumulatively considerable if the project will <br />comply with the requirements in a previously approved plan or mitigation program <br />(including, but not limited to, water quality control plan, air quality attainment or <br />maintenance plan, integrated waste management plan, habitat conservation plan, natural <br />community conservation plan, plans or regulations for the reduction of greenhouse gas <br />emissions) that provides specific requirements that will avoid or substantially lessen the <br />cumulative problem. To be used for this purpose, such a plan or program must be specified <br />in law or adopted by the public agency with jurisdiction over the affected resources through <br />a public review process. In relying on such a plan or program, the City should explain <br />which requirements apply to the project and ensure that the project’s incremental <br />contribution is not cumulatively considerable; and <br />(f) Whether the project may cause a substantial adverse change in the significance of an <br />archaeological or historical resource. <br />The City may use a threshold of significance (as that term is defined in State CEQA <br />Guidelines section 15064.7) to determine whether a project may cause a significant environmental