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 City of Solana Beach
Section 4
Shoreline and Coastal Bluff Management Strategies Draft MEIR
Cumulative Impacts
4.0 CUMULATIVE IMPACTS
This chapter evaluates the cumulative impacts that could result from the implementation of each
of the project alternatives as required by CEQA Guidelines for MEIRs ( 15175). This MEIR is
evaluating four broad policy and program alternatives, and is, therefore, required to discuss the
potential cumulative impacts associated with each alternative and subsequent projects.
By definition and according to CEQA, cumulative impacts are two or more individual impacts
that, when considered together, are considerable or that compound or increase other
environmental impacts. That is, the cumulative impact of several projects is the change in the
environment that results from the incremental impact of the project when added to other closely
related past, present, and/or reasonably foreseeable, probable future projects. Cumulative
impacts can result from individually minor, but collectively cumulative projects taking place over
a period of time.
According to revisions made to the CEQA Guidelines in 1998, a lead agency may determine
that a project's contribution to a cumulative impact is not "cumulatively considerable" if the
project will comply with the requirements in a previously approved plan or mitigation program
that provides specific requirements that will avoid or substantially lessen the cumulative problem
within the geographic area in which the project is located. (CEQA Guidelines, 15064, subd.
(i)(3).). Similarly, a lead agency may determine that the incremental impacts of a project are not
"cumulatively considerable" when they are so small that they have a de minimus contribution to
a significant cumulative impact caused by other projects that would exist in the absence of the
proposed project. A de minimus contribution means that the environmental conditions would
essentially be the same whether or not the project is implemented. (CEQA Guidelines,
15064, subd. (i)(4), 15130, subd. (a)(4).) Although the specific Guidelines provisions articulating
these principles are currently under attack in an appeal pending in the Third District Court of
Appeal in Sacramento (Communities for a Better Environment et al. v. California Resources
Agency, Case No. C038844 ), no party in that case, to the City's knowledge, is questioning the
general principle that, in some instances at least, a very small incremental contribution to a
larger cumulative problem can be effectively mitigated by compliance with policies in an adopted
plan that effectively render that incremental contribution to a level that is "less than cumulatively
considerable." (See CEQA Guidelines, 15130, subd. (a)(3); Save Our Peninsula Committee
v. Monterey County Board of Supervisors (2001) 87 Cal.App.4th 99, 140.) Furthermore, the
pending appeal does not involve CEQA provisions dealing with MEIRs, which contemplate that,
where such documents properly cumulative impacts, future environmental documents need not
address those same issues again. (CEQA Guidelines, 15176 - 15178.)
Consistent with those provisions dealing with MEIRs, this chapter will evaluate the potential
cumulative impacts that may be associated with each alternative and subsequent projects
discussed in this MEIR when combined with other past, present, and reasonably foreseeable
future actions undertaken by the same or other agencies, private parties, and/or persons. The
affected environment is described first, followed by a general discussion of the potential
cumulative impacts that could be anticipated.
Project No. 323530000
Page 4-1
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