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Response to Comment L18: Lisa Lacey dated August 12, 2024 <br />Comment L18.1: This comment states that the proposed Project would result in additional congestion and <br />displace current businesses. <br />Response L18.1: Draft SEIR Section 5.13 Transportation, details that Senate Bill (SB) 743 changes include <br />the elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as the <br />basis for determining significant impacts. As part of the 2019 amendments to the State CEQA Guidelines, <br />SB 743 directed that the revised CEQA Guidelines "shall promote the reduction of greenhouse gas <br />emissions, the development of multimodal transportation networks, and a diversity of land uses" (Public <br />Resources Code Section 21099[b][1 ]); and that "automobile delay, as described solely by level of service <br />or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant impact <br />on the environment" (Public Resources Code Section 21099[b][2]). As such, pursuant to Public Resources <br />Code Section 21099(b)(2), the SEIR focuses on analysis of Vehicle Miles Traveled (VMT) criteria and <br />improvements to the circulation system along the Project's frontage to accommodate buildout of the <br />proposed Project, pursuant to the City's recent General Plan Update. Further yet, the SEIR is not required <br />to analyze impacts related to traffic congestion. Nevertheless, a Traffic Impact Analysis was prepared for <br />the Project and is publicly available on the City's Project website. This comment will be forwarded to all <br />decision makers as part of the staff report for the Project. <br />Regarding the displacement of businesses, CEQA is an environmental protection statute that is concerned <br />with physical changes to the environment (CEQA Guidelines Section 15358(b)). The environment includes <br />land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance <br />(CEQA Guidelines Section 15360). The Project's potential economic and social effects are not considered <br />effects on the environment (CEQA Guidelines Sections 15064(e) and 15131 (a)). Thus, consistent with <br />CEQA, the Draft Supplemental EIR includes an analysis of the Project's potentially significant physical <br />impacts on the environment and does not include substantial discussion of the Project's economic or social <br />effects, including the displacement of businesses. <br />42 <br />