New Initial Study Checklist

By Eric Parfrey, President, S.F. Bay Chapter
BASELINE Environmental Consulting

As planners we must educate ourselves and incorporate into our daily practice all of the new changes that have been amended into the daddy of all planning laws, the California Environmental Quality Act. As of February 1999, a wave of major amendments to the CEQA Guidelines becomes applicable. Perhaps the single most significant and noticeable change to CEQA was the adoption of a totally updated and revamped Initial Study Checklist (now included as Appendix G to the Guidelines). The new checklist is only a suggested form, but new introductory text notes that "lead agencies should normally address the questions" that are relevant. This explicit direction is necessary since the previous list of "Significant Effects" (the old Appendix G) has been deleted. Many planning agencies and private consultants try to use the latest format of the checklist that is recommended by the CEQA Guidelines.

The text of the Initial Study and the other CEQA amendments may be viewed in PDF format at the Resources Agency site: www.ceres.ca.gov/ceqa. However, it is not possible to download a Word or WordPerfect copy of the Initial Study directly from the Resources Agency site (you must cut and paste the PDF text into a word processing page.). AEP is pleased to provide a copy of the Initial Study in either a Word or WordPerfect file. Click on the icons below.

Word Version

WordPerfect

Prominent AEP members such as Curtis Alling, chair of the AEP Legislative Committee, and Al Herson had a major hand in suggesting the language and other changes to the Initial Study, and many of their suggestions were adopted by the Resources Agency. Although the new format may cause some slight discomfort to aging baby boomers who like routine in their professional lives, overall the changes make sense and should be a welcome addition. The new Appendix G checklist contains new and clarified questions that pose new thresholds of significance to help us make a determination whether a public and private development project may have significant environmental impacts. Outdated, awkward, and ambiguous phrases have been eliminated and references to relevant State laws, documents, and specific potential impacts have been added.

First, the bad news: all of the topical sections have been rearranged in alphabetical order starting with "Aesthetics" and a new (and excellent) "Agricultural Resources" section. The list looks totally different for us old-timers. The good news is that the number of questions that must be answered has increased only slightly, from 78 questions on the old checklist to 87 under the new list. No new broad environmental topics have been added, and some of the dated archaic questions have been deleted. For example, the two vague questions under the old "Energy and Mineral Resources" section about the project’s consistency with energy conservation plans and whether the project "uses non-renewable resources in a wasteful and inefficient manner" (how do you honestly assess an auto-dependent project?) are gone and in their place are two direct questions about mineral resources only. And one of the "mandatory" questions (related to long-term vs short-term effects) is gone for good!

The "Hazards" and "Noise" sections have been expanded and transformed from a series of vague inquiries about health hazards to very specific questions about hazardous materials and other health issues. For the first time, the noise questions correctly differentiate between an increase in temporary versus permanent noise levels. The "Transportation/Traffic" section contains a very helpful definition of a increase in traffic "in relation to the existing traffic load and capacity of the street system," and asks whether level of service standards have been exceeded. (But why did the previous traffic question about "barriers for pedestrians and bicyclists" get deleted?)

Both the "Geology" and "Hydrology" sections have received major surgery to correct the convoluted series of questions and eliminate the repetition about groundwater impacts. (We’re glad to see that our favorite question about hazards due to seiche and tsunami is still there, but what happened to volcanic hazards?) The "Biological Resources" section has also been updated with relevant references to the appropriate wildlife agencies, Section 404 permits, and habitat conservation plans.

From my perspective, the most significant and welcome change to the Initial Study checklist is the addition of a series of specific questions in the "Utilities and Service Systems" section which relate to a project’s potential impacts on wastewater treatment capacity and discharge, water supplies, and landfills. Finally, we have no-nonsense questions that pinpoint key infrastructure issues and impacts, eliminating the wiggle room in the old questions. At least by the time the new millennium rolls around, and new water supplies in California become even more scarce, our trusty checklist will ask whether a project has "sufficient water supplies available to serve the project from existing entitlements and resources" and whether the construction or expansion of needed infrastructure facilities "could cause significant environmental effects."