HomeMy WebLinkAboutAgenda Statement 1976/04/27 Item 13CITY OF CHULA VISTA
COUNCIL AGENDA STATEMENT
ITEM N0.
13
FOR MEETING OF: 4/27/76
ITEM TITLE:Resolutior~G1~+2 -Supporting proposed amendments to the State EIR Guidelines
SUBMITTED BY~ D. J. Peterson, Chairman, Environmental Review Committee
ITEM EXPLANATION
On February 26, 1976 the Environmental Control Commission recommended that the Council
support the Association of Enviror~nental Professionals (AEP) proposed amendments to
CEQA. The Council received the recommendation on March 23, 1976 and referred the matter
to the Environmental Review Committee for a recommendation.
Subsequently, the Secretary for Resources and the Director of the Office of Planning
and Research of the State of California have proposed amendments to the State EIR
Guidelines which would implement most of the AEP's proposals.
The Environmental Review Committee has examined the Guideline amendments and found
that they would generally streamline the environmental review process and cut down
on the amount of paper work. The E.R.C. recommended support of the amendments with
several exceptions as outlined in the attached report.
tXHIBITS ATTACHED
Agreement Resolution X Ordinance Plat Other X
Environmental Document: Attached Submitted on
STAFF RECOMMENDATION:
Concur with Environmental Review Committee's recommendation.
BOARD/ COMMISSION RECOMMENDATION:
The Environmental Review Commiatee recomm n t a ~~}}e~,Cc}~ ncil support the EIR
Guideline amendments with the exception of~~~a~ ~o~ii ~`i dfis outlined i n the
attached report. by the
Cii;~ Cc:.:~cil
COUNCIL ACTION
Cl1UiC~. `'d? ~~t;~., ~;z.1.:~OZ'113.2.
Dated ~~-a 7'_,~
5-75)
/ 3
Apri 1 21,, 1976
~~
To: The Honorable Mayor and City Council
Via: City Manager
From: Environmental Review Committee, D. J. Peterson, Chairman
Subject: Recommendation regarding proposed amendments to the State EIR Guidelines
A. At a press conference held on March 17, 1976 by the Secretary for Resources
and the Director of the State Office of Planning and Research, it was announced
that hearings will be held May 4th and 7th on proposed revisions to the State EIR
Guidelines (Cal. Admin. Code). These amendments are the result of in-depth
studies conducted by both the Resources Agency and the Office of Planning and
Research. Among the major amendments are the following:
1. A project proponent will not be permitted to contract directly with
a consultant for the preparation of draft EIR's, rather, all payments
to the consultant must be channeled through the lead agency and the
draft EIR, when completed, must be submitted to the lead agency by the
consultant.
2. The concept of the phased EIR is validated by the Guidelines.
3. The concept of an EIR focusing on only those issues which have a
potential for significant effect is included in the amendments.
4. One provision clearly states that it is not necessary that a Registered
Professional prepare EIR's, however, they may be required to prepare
technical data.
5. The initial study (IS) process is given much more detailed attention;
the content of an initial study is specified and a special format is
appended to the Guidelines.
6. Examples of activities which may have a significant effect have been
expanded and given more detail.
7. The content of negative declatations (ND's) has been expanded to include
such information as mitigation measures which have been incorporated in
the project to avoid potential significant impacts. An initial study
can therefore be used as a tool to encourage the project proponent to
modify his project or incorporate mitigation measures to avoid the
preparation of an EIR.
8. It is noted that EIR's should be prepared when there is serious public
controversy concerning the environmental effects of the project.
9. It is specified that EIR's not be prepared when the project's potential
impacts are so indefinite and unpredictable that it could not be deter-
mined if the project could have an adverse effect.
10. Specific methods for giving public notice of the availability of draft
EIR's is provided.
Honorable Mayor and City Council
Proposed amendments to State EIR Guidelines
page 2
11. A written statement of Overriding Considerations when an agency proposes
to approve a project with substantial environmental effects, is mandated
by one provision of the amendments.
12. Guidelines for the preparation of the energy conservation element of an
EIR are provided in an appendix to the Guidelines.
B. Many of these amendments are identical to the amendments to CEQA as proposed
by the Association of Environmental Professionals. The Council referred a
proposed recommendation from the Environmental Control Commission supporting the
AEP's CEQA amendments to staff and the Environmental Review Committee for a
recommendation. Because the Guideline amendments are so similar to the AEP's
proposal and the Secretary for Resources is holding hearings prior to adopting
revisions, it is now more appropriate to comment on the Guide line revisions
rather than AEP's recommended revisions to CEQA.
C. The proposed revisions, if adopted, will result in a more efficient environ-
mental review process. The inclusion of mitigation measures in ND's will probably
cause more projects to be processed with a ND rather than an EIR. Allowing EIR's
to discuss only areas with possible significant impact will reduce the volume of
EIR's. Chula Vista has been processing EIR's in this method for several months
now.
Attached is a section by section summary of the proposed revisions.
D. There are several sections which Council should consider opposing. They are
as follows:
1. Notice of Determination.
Once the decision-making authority takes action on a project for which an EIR
was prepared, a notice of determination is filed with the County Clerk. This
change would require all mitigation measures incorporated into a project to be
listed in the notice. The purpose of the notice of determination is to begin
the statute of limitations period for a legal challenge in an EIR. The proposed
amendment would change the notice into a "mini-EIR" which is inappropriate.
2. Cumulative Effect.
The Guidelines redefine cumulative effect to include impacts from more than
one project. This interpretation will be difficult to administer although
this is not as serious a problem as would result from the AEP proposed defini-
tion which includes past, present, and future projects.
3. EIR Preparation.
Two alternative methods of preparing EIR's were included in the amendments to
stimulate discussion. The first alternative would simply require the agency
to prepare the EIR on all projects either directly or by contract. This is
the precise wording from CEQA and would mean that the City would either
prepare EIR's itself or by contract with costs paid by the applicant in either
case. No draft EIR could be submitted by the proponent.
The second proposal would allow the project proponent to have a draft EIR
Honorable Mayor and City Council
Proposed amendments to State ETR Guidelines
page 3
submitted to the agency, however, this would be allowed only subject to
various stringent requirements, including having all costs channeled through
the agency to the consultant preparing the document. Discussions with the
Finance Department indicate that the second alternative would require a rather
complicated accounting system and the first alternative is preferable on the
basis of staff time to handle the funds.
The Environmental Review Committee therefore recommended the first alternative.
E. RECOMMENDATION
Adopt a resolution supporting the proposed State EIR Guideline revisions with the
following qualifications:
1. The definition of cumulative effect (15023.5) and the content of a Notice
of Determination (15085 h) should not be revised.
2. The second alternative for the preparation of an EIR (15061 b) should not
be implemented. The first alternative is much more simple and satisfactory.
PROPOSED REVISIONS TO STATE EIR GUIDELINES
The following is a list of all the substantial changes proposed by
the Office of Planning & Research and the Secretary of Resources,
and a brief explanation of the purpose of the amendment.
15011.5 Additional Policies
This is a list of the major policies the courts have
found to be implicit in CEQA
15013 Time of Preparation
Environmental documents would have to be prepared as
soon as "feasible" vs, as soon as "possible".
Agencies will have to encourage private project proponents
to incorporate environmental considerations in project
formulation.
Environmental documents will have to be included in the
regular project reports.
15023.5 Cumulative Impacts
This definition is expanded to include small changes
from a number of projects.
15037 (c) Project
Greater distinction between a "project" and the "discretionary
approval" is provided.
15040 Significant Effect
This section is expanded to list the feature which if
affected by a project, could have significant effect.
15060 General Rule
An explanation of the limitation of the applicability of
CEQA is provided.
15061 (b) EIR Preparation: Alternative 1
The draft EIR would have to be prepared by the agency either
directly or by contract.
15061(b) EIR Preparation: Alternative 2
The draft EIR could be submitted by the applicant only
if it were not prepared by the applicant or a consultant
hired directly by the applicant and the following
conditions are met:
1. The draft EIR is prepared by a consultant.
2. Payments•are channeled through the agency.
3. The agency provides guidence on the contents
of the draft EIR.
4. The draft EIR is submitted directly to the agency.
15065 (b) Lead Agency
Definitions of City's role in prezoning/annexation is
provided.
Guidence for a responsible agency when a lead agency does
not comply with CEQA is provided.
15068.5 General Plan EIR & Subsequent Projects
After the preparation of a General Plan EIR subsequent
EIR's need only to refer to the General Plan EIR acid
limit the analysis to areas not specific enough in the
General Plan EIR.
15069 Multiple Projects
15069.5
References to phased projects are eliminated from this
section.
Phased EIR
On long range "capital" projects involving several
- discretionary approvals from genernmental agencies, ---
the preparation of an EIR may be phased as she project
definition becomes more specific.
15069.6 Lead Agency established by Statute
15070 (d) LAFCO Grandfather
These amendments do not pertain to the City.
15075 Use of Registered Professional's in Preparation of EIR's
The use of Registered Professionals is not required in -
the preparation of EIR's.
Any professional report used in the preparation of an EIR
must be cited.
15080 Initial Study
This section of the guidelines is proposed to be greatly
expanded. The major sections are as follows:
1. The purposes of an Initial Study
2. The contents of an Initial Study
3. The uses for which an Initial Study may be used.
4. A specific "suggested" format for the submission
of information.
These revisions plus the appendices H & I are the heart
of the directions proposed in these amendments. Special
attention should be given them.
15081 (c) Examples of Significance
Examples of changes which may have a significant effect
are proposed to be expanded and placed in an appendix.
15083 (b) Negative Declaration
A Negative Declaration will now include mitigation measures.
15084 Decision to Prepare an EIR
Circumstances under which an EIR must be prepared has
been given more detail. The specific example of public
controversy requiring the preparation of an EIR has been
included.
15085(d) Public Review
Specific methods of providing public notice are included.
The include:
1. Newspaper publication
2. Posting of project site
3. Direct mailing
4. PubJ.ic service announcements
15085 (h) Notice of Determination
A notice of determination for a project for which an EIR
has been prepared will now include a statement of the
mitigation measures adopted by the agency.
15088 Statement of Overriding Considerations
This statement would be mandatory and include reasons to
support the approval action.
15116 Class 16 Exemptions
Transfer of ownership to create a park,
Note: various do not effect the
City and are not discussed herein.
15117 Class 17 Open Space
This Class would exempt the acceptance of open space
easements.
15119-20 LAFCO Exemptions
These amendments are regarding exemption in the processing
of annexations. There is no chance in the current
interpretation of the guidelines.
15140 EIR Contents
A brief summary of the proposed action and its consequences
would be required. Appendices are authorized and may be
in separate volumes on file but available for public
review.
All documents used in the preparation of an EIR must be
referenced.
An interdisciplinary team preparation of EIR's is mandated.
When an Initial Study has been used to focus an EIR, the
IS shall be attached to the E_TR.
15143 (c) Mitigation
This section of an EIR must distinguish between those
mitigation measures which are included in the project
and those which are not but which could be.
15143 (d) Alternatives
An economic consideration in determining the feasibility
of a project has been included.
15149 P,eference
Documents may be incorporated by reference if they are
briefly summarized and otherwise available for public
review.
15150 Standards
EIR must be adequate and complete, not perfect.
Appendix F Energy Conservation
Appendix G Significant Effects
Appendix H Environmental Information Form ('YS application)
Appendix ~I Environmental Checklist Form (Evaluation Form)