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1 <br /> John Funderburg,Principal Planner <br /> October 30, 2018 <br /> Page 16 <br /> 3. The SDEIR Falls to Adequately Analyze the Project's <br /> ' Cumulative Traffic hupacLs. <br /> An EIR must discuss a P'roject's significant cumulative impacts. CEQA <br /> Guidelincs § 15130(a). A legally adequate cumulative impacts analysis views a particular <br /> ' <br /> project over tirne and in wrijutiction with other related past, present, and reasonably <br /> fomrrseeable future prniects whose impacts might compotutd or interrelate with those of <br /> the project at hand, "Ctunulative impacts can result from individually minor but <br /> icollectively significant prnlects taking place over a period of time." Id. § i 5355(b). A <br /> project has a significant cumulative effect if it has an impact that is individually limited <br /> but"cumulatively considerable "Id §§ 15065(a)(3), 15130(a). "Cumulatively <br /> considerable" is defined as meaning that "the incremental effects of au individual project <br /> are signiftc+ant when viewed in connection with tate effects of pits( projects, the etTects of <br /> other current projects, and the effects of probable future projects."Id. <br /> ' Curnulativc Impacts analyses are necessary because"environmental damage often <br /> occurs inerementully from a variety of small sources [thati appear insignificant when <br /> 1 considered individually,but assume threatening dimensions when considered collectivcly <br /> with other sources with which they interact." Communities fibr a Beller Lmohonmeni v. <br /> Cal. Resources Agentn,,(2(H)2) 103 Cal.App.4th 98, 114. oven-uled on other grounds. <br /> 14 <br /> licit the SDEIR's cumulative traffic analysis is cursory and incomplete and does not <br /> Orae close to meeting,CEQA's clear legal standard. <br /> ' The document conducts lite first step of the analysis, identification of the approved <br /> and pendalg projects in the vicinity,but it then declines to analyze the environmental <br /> impacts from certain of the approved prolZCls. In particular. the SDEIR fails to arnalyze <br /> the cumulative environmental effects resulting from the Mariposa Lakes,project. The <br /> ' Mariposa Lakes project,approved by the City of Stockton in 2008,would develop 10,514 <br /> dwelling units on 3,810 acres immediately north of the landfill. SDEIR at III-16; see 01,so <br /> Mariposa Lukes Plaimcd Community, City of Stockton Legislation Text General Plan <br /> ' Neighborhood Discussion;and Mapping Stockton's Future(MnripoNa Lakes documents), <br /> attached as Exhibit H. The SDEIR states that the inmpacis of the Mariposa Lakes project <br /> are not evaluated in the cumulative traffic analysis because, according to Stockton <br /> planning staff, the project is not expected to be operational in the Forward lundiill <br /> Project's lifetime(i.e., before 2036). SDEiR at IV.B-18. <br /> ' The SDL-'IR's approach is misguided. The fact drat a project is tiot exl-wvled to be <br /> operational dues not provide the accessary assurance tint it will not be developed within <br /> the next eighteen years. The Mariposa Lakes applicant received en(itlemcnts for the <br /> project in 2008.Consequently, the Project could certainly be developed. In fact,as <br /> SH UT L-, MIIIALY <br /> VEIN bLRGERto. <br /> 1 <br />