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Proposal for CEQA Analysis <br />Garry Avenue Business Park <br />2. Project is consistent with GP and Zoning <br />a) Initial Study/Negative Declaration or Mitigated Negative Declaration <br />b) EIR <br />July 26, 2021 <br />Page 3 <br />La) Categorical Exemption <br />Due to the project site's size and proposed increase in square footage, the project would not qualify for a <br />categorical exemption, including a Class 32 exemption which is limited to 5-acres or a Section 15302 <br />Replacement or Reconstruction exemption which requires the replacement structure to be of substantially <br />similar purpose and capacity as the structure replaced. Although the existing buildings total more square <br />footage than the proposed building, the anticipated tenancy of the proposed building would be different <br />than the existing buildings. <br />Lle) CEQA Guidelines Section 15168 Streamlining <br />Again, since the proposed project is assumed to be consistent with the site's General Plan and zoning <br />designation in this scenario, the proposed project may be consistent with CEQA Guidelines Section 15168, <br />Program EIR. A later activity in a program, such as a project that implements a General Plan, does not need <br />additional CEQA analysis if its impacts would be within the scope of the impacts disclosed in a program EIR. <br />Similar to the 15183 Streamlining process, EPD would prepare a modified initial study checklist to document <br />the fact that the project's impacts are within the scope of the impacts identified in the General Plan EIR. If <br />only minor clarifications are needed to make the General Plan EIR sufficient for the project, then the checklist <br />needed to satisfy the requirements of the 15168 Streamlining process also can be an addendum to the <br />General Plan EIR. <br />l.c) CEQA Guidelines Section 15183 Streamlining <br />Since the proposed project is assumed to be consistent with the site's General Plan and zoning designation <br />in this scenario, the proposed project may be consistent with CEQA Guidelines Section 15183, projects <br />consistent with a community plan. A project is eligible for 15183 Streamlining if it would create no peculiar <br />environmental effects that are not addressed as significant effects in the General Plan EIR or cannot be <br />substantially mitigated by the imposition of uniformly applied development policies or standards. EPD will <br />prepare an Initial Study and will thoroughly review the project, the Revised General Plan EIR, the project's <br />impacts to determine if the project can be streamlined under Section 15183. The Initial Study will guide the <br />appropriate CEQA path. Based on the proposed uses and the City's overview of the studies completed to - <br />dale, significant and unavoidable uses are not anticipated; therefore, the Initial Study could lead to either <br />15183 streamlining or a Mitigated Negative Declaration (MND). <br />l.d) Addendum to Revised General Plan EIR (2021) <br />CEQA Guidelines Section 15164, Addendum to an EIR or Negative Declaration, states that the lead agency <br />"shall prepare an addendum to a previously certified EIR [or adopted Negative Declaration] if some changes <br />or additions are necessary but none of the conditions described in Section 15162 calling for preparation of <br />a subsequent EIR (SEIR) occurred." In turn, Section 15162 requires a SEIR if: <br />(1) there are substantial changes proposed to the project which will require major revisions of the <br />previous EIR; <br />(2) there are substantial changes in circumstances under which the project is undertaken which will <br />require major revisions of the previous EIR due to the involvement of new significant environmental <br />effects or a substantial increase in the severity of previously identified significant effects; or <br />