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Analyzing Cumulative Impacts

This article provides an overview of the requirements and guidelines for analyzing cumulative impacts in environmental assessments. It covers the definition of cumulative impacts, the scope of the analysis, determining significance, and the necessary documentation.

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Analyzing Cumulative Impacts

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  1. Analyzing Cumulative Impacts Steven Blum

  2. Requirements:Cumulative Impacts • CEQA requires that we consider the impacts of the project in the context of all other projects in the area that might contribute to additive environmental impacts. • Guidelines §15130 requires that a cumulative impact analysis be included in an SED for a project with any significant impacts

  3. What is a Cumulative Impact? • Two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts. (a) The individual effects may be changes resulting from a single project or a number of separate projects. (b) The cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time. Guidelines §15355

  4. Remember! • Applies to all types of environmental impacts, not only water quality • Applies to all projects that could have similar impacts, not only TMDLs or water-related projects

  5. Cumulative Impact Analysis • The cumulative impact analysis must identify: • The cumulative incremental effect of the project • A brief explanation of why each cumulative effect is or is not considered considerable or significant • The discussion must reflect the severity of the impacts and their likelihood of occurrence

  6. Cumulative Impact Analysis:Projects to Consider • A list of past, present, and reasonably foreseeable future projects producing related or cumulative impacts • Projects under consideration but not yet approved, for example, general plans or HCPs • Projects for which applications have been submitted • Project ideas under serious public discussion • However, we are not required to speculate! (Guidelines §15145)

  7. Cumulative Impacts

  8. Defining the Scope of the Analysis • Define the geographic scope of the area affected by the cumulative effects • Summarize the expected environmental effects to be produced by those projects • Analyze the cumulative impacts of the related projects

  9. What is NOT a Cumulative Impact? • If your project would have NO Impact in a topic area it will not contribute to a cumulative impact to that resource area (Refer to responses on your checklist) • Cumulative impacts adequately addressed in a prior environmental document, community plan, or State Board SED (Guidelines §15130(d)&(e)) • A project’s contribution is “less than cumulatively considerable” if its proponent is “required to implement or fund its fair share of mitigation designed to alleviate the cumulative impact” (Guidelines §15130(a)(3))

  10. How to Determine Significance of Cumulative Impacts • Review other projects • Determine where there are or will be similar impacts • Determine the timing, location, and magnitude of the impacts • Apply standard thresholds of significance • Apply Fair Argument to determine significance If an impact is cumulatively considerable, treat it as significant in the SED

  11. CEQA Requirements for Cumulative Impact Analysis Determine whether the project contributes to a significant cumulative impact Determine whether your contribution is “considerable” in cumulative context Require mitigation to avoid contribution, if feasible Considerable contribution = significant effect Small ratio can be “considerable” Small contribution can be “considerable”

  12. Scope of the Cumulative Impact Analysis Define the cumulative area of effect Might be beyond watershed – depends upon context Different impacts have different areas of effect CEQA’s requirements: Plan or projections approach Adopted plan or projections that describe the cumulative impact List approach List of past, present, and reasonably foreseeable future projects

  13. Speculation v. Forecasting CEQA does not require speculation If analysis would be speculative, explain why CEQA does require forecasting Reasonable, good-faith effort is sufficient Places to look: General plan or capital improvement plans Projects approved, but not built Applications on file

  14. Questions?

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