ENVIRONMENTAL PLANNING DEVELOPMENT SOLUTIONS, INC. (2)

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Proposal for CEQA Analysis July 26, 2021 Gamy Avenue Business Park Page 8 3. Environmental Documentation - Initial Study/Section 15183 Streamlining 3.1. Administrative Draft Initial Study As discussed above, EPD assumes the project will be proceeding after the City completes the public drafts of the GPU and EIR. Therefore, the CEQA compliance approach will be to tier off of that EIR in which it will qualify for CEQA review under Section 15183 of the California Code of Regulations, which stipulates that if a project is consistent with the land use and zoning of an adopted General Plan, CEQA "shall not require additional environmental review, except as might be necessary to examine whether there are project - specific significant effects which are peculiar to the project or its site." Completing the analysis pursuant to CEQA Guidelines Section 15183 would focus the effort on a narrow range of potentially significant impacts, including those which: • Are peculiar to the project or the parcel on which the project would be located; • Were not analyzed as significant effects in a prior EIR on the Zoning Action, General Plan or community plan with which the project is consistent; • Are potentially significant off -site impacts and cumulative impacts which were not discussed in the prior EIR prepared for the general plan, community plan or zoning action; • Are previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR. To evaluate the project pursuant to the above, EPD will prepare an IS for the project addressing each of the environmental topics and through this effort evaluate the applicability of Section 15183 to the project. An administrative draft of the IS will be provided to the City for review. City comments will be incorporated into an updated document. One round of review is expected. 3.2. Public Draft IS/Section 15183 Streamlining and MMRP Section 15183 does not require a public circulation of the tiering document, but in preparation for the hearing body's staff report packages, EPD will prepare the final public draft IS/Section 15183 Streamlining document, including revisions that may be necessary after the Planning Commission meeting, including responses to comments submitted on the CEQA document. Because the scope of changes is not known at this time and until the hearing occurs, the fee associated with this task is a budget amount. As part of this task, EPD will also prepare an MMRP for the project incorporating the General Plan EIR mitigation measures and any project -specific measures. The MMRP will use the City's typical format for such documents. EPD will review the MMRP with the to ensure the steps to compliance with each mitigation measure are appropriate and feasible. 4. Environmental Documentation - Initial Study/Mitigated Negative Declaration This scope of work assumes that after preparing the Task 3 efforts, the applicant will instead move forward with the GPA, ZC and DPR due to delays on the City's GPU and EIR. Therefore, the IS prepared under Task 3 would require revisions to remove references to tiering off of the GPU EIR and instead be drafted as a standalone project CEQA document and in support of an MND. EPD expects and assumes that previously prepared technical studies, prior to any revisions made to account for the Task 3 approach will be adequate for use in the IS.