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City of Santa Ana – The Bowery <br />May 11, 2020 <br />Page 20 of 28 <br />projects, and the effects of probable future projects.” (CEQA Guidelines <br />§15065(a)(3); Banning Ranch Conservancy v. City of Newport Beach (2012) 211 Cal. App. 4th <br />1209, 1228; see also CEQA Guidelines §15355(b).) <br />A cumulative impacts analysis must include all “past, present, and probably future <br />projects producing related or cumulative impacts” or “[a] summary of projections <br />contained in an adopted local, regional or statewide plan, or related planning <br />document.” (CEQA Guidelines 15130(b)(1-2)). A probable future project should be <br />considered once the environmental review for the project is underway. (San Franciscans <br />for Reasonable Growth v. City & County of San Francisco (1984) 151 Cal. App. 3d 61.) <br />The City identified eleven projects in Santa Ana, eight in Irvine, five in Tustin, <br />and two in Newport Beach when calculating the cumulative impacts for its <br />transportation analysis. While a list approach is acceptable under CEQA, the list <br />must include all past, present, and probably future projects that could contribute <br />to the Project’s impacts. This cumulative impact analysis is flawed and should be <br />updated to include, at least, the potential impacts of the Congregate Care Facility <br />and Staybridge Hotel in Irvine.2 The Congregate Care Facility is a 424,113 square <br />foot facility located just two miles south of the Project site; and the 200+ room <br />Staybridge Hotel will be located just one mile west of the Project site. The <br />Congregate Care Facility project has already been approved by the City of Irvine; <br />and the Staybridge Hotel is currently under construction. Both projects should <br />be considered in the City’s CEQA analysis. <br />I. The DEIR Fails to Describe or Adopt Feasible Mitigation Measures <br />A fundamental purpose of an EIR is to identify ways in which a proposed <br />project's significant environmental impacts can be mitigated or avoided. (Pub. <br />Resources Code §§21002.1(a), 21061.) To implement this statutory purpose, an <br />EIR must describe feasible mitigation measures that can minimize the project's <br />significant environmental effects. (CEQA Guidelines §§15121(a), 15126.4(a).) "A <br />gloomy forecast of environmental degradation is of little or no value without <br />pragmatic, concrete means to minimize the impacts and restore ecological <br /> <br />2 The location and development stage of these projects may be found at <br />https://cityofirvine.maps.arcgis.com/apps/MapTour/index.html?appid=0429065850 <br />ec4dcab5ba5856a497f42a.