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Some guidance for dealing with growth-inducing impacts when the location and extent of the impacts is <br /> to some extent speculative is provided by the Court's ruling in Napa Citizens for Honest Government v. <br /> Napa County Board of Supervisors ([2001] 91 Cal. App. 4th 342). The sufficiency of analysis of growth- <br /> inducing impacts was an issue contested in that case. In its decision, the Court provided the following <br /> guidance: <br /> ...the EIR must discuss growth-inducing impacts even though those impacts are not <br /> themselves a part of the project under consideration, and even though the extent of the <br /> growth is difficult to calculate. <br /> It does not follow,however,that an EIR is required to make a detailed analysis of the impacts of a project <br /> on housing and growth. Nothing in the [CEQA] Guidelines, or in the cases, requires more than a <br /> general analysis of projected growth. [Emphasis added.] <br /> Neither CEQA itself, nor the cases that have interpreted it, require an EIR to anticipate and mitigate the <br /> effects of a particular project on growth [in] other areas. <br /> The Project would increase the availability for disposal of biosolids, a regulated waste stream in <br /> California. Although the Project does not include any applications for sewer plant expansions, it could <br /> remove or reduce an obstacle to growth because the availability for disposal of biosolids waste would be <br /> increased as a result of this Project. <br /> If the Project were fully utilized,up to 2,000 tons per day of biosolids disposal could be made available to <br /> entities within and outside of Kern County. Biosolids disposal is not restricted by the availability of local <br /> landfills in the same way that sewage disposal and water supply needs must be accommodated by the <br /> local systems. Biosolids can be hauled to other distant areas by long haul trucks. <br /> Conclusion: <br /> Although the Project will not be able to take more than 2,000 tons per day of biosolids, and would not <br /> completely compensate for the reliabilityof other biosolids facilities, either disposal, land application, or <br /> recycling, serving southern California, it could nonetheless remove or reduce an obstacle to some level of <br /> growth. It cannot be known precisely where future growth may occur in Antelope Valley, Los Angeles <br /> County, and Orange County. It is,however,reasonable to assume that most of the growth would occur in <br /> accordance with current city and county general plans. By providing increased reliability for disposal of <br /> biosolids for sewage facilities, the Project could enable such jurisdictions to approve a larger aliquot of <br /> their planned growth than might have been possible under existing biosolids facilities without the Project. <br /> Removal or reduction of an obstacle to growth could accommodate growth that has already been planned <br /> for in those areas. Growth that could occur as a result of the removal of this obstacle could affect <br /> agricultural resources, air quality, biological resources, cultural resources, hydrology and water quality, <br /> noise, transportation and traffic, and utilities and services. It is therefore, growth inducing and the <br /> impacts are significant and unavoidable. <br /> SECTION IV. FINDINGS REGARDING CONSIDERATIONS WHICH MAKE CERTAIN <br /> ALTERNATIVES ANALYZED IN THE FINAL ENVIRONMENTAL IMPACT <br /> REPORT INFEASIBLE. <br /> Findings of Fact—Section 15091 March 15,2016 <br /> H.M. Holloway Landfill Modification Project Final Board of Supervisors <br /> 48 <br />