California Department of Resources Recycling and Recovery (CalRecycle) 

LEA Advisory #36—February 4, 1997

CEQA Cumulative Impact Analysis

To All Local Enforcement Agencies:

Due to the recent increase in landfill closures, refuse formerly disposed in landfills located near the source of generation is now being transported to more distant facilities, including out of state. It has come to the attention of CIWMB staff that some California Environmental Quality Act (CEQA) documents prepared for this type of project may not address or may fail to adequately address potential cumulative impacts from such an action.

CIWMB staff would like to bring to your attention the requirements of CEQA with respect to cumulative impact analyses. We encourage LEAs, when consulting with lead agencies or commenting on documents, to inform the lead agency of any similar projects or projects with related impacts that may need to be evaluated in a cumulative impact analysis.

Although a lead agency may find that a specific impact is less than significant within the scope of its jurisdictional analysis, the same action on a regional scale may contribute to or create a significant cumulative effect. For example, the additional truck traffic from a proposed project which would not significantly impact a particular length of highway when considered by itself could create a substantial cumulative impact when combined with traffic from other projected or reasonably anticipated sources.

Court interpretations of CEQA have further defined CEQA's statutory provisions. For example, a cumulative impact discussion may be found inadequate if it does not include the elements listed in CEQA Guidelines Section 15130 (Cumulative Impacts); specifically, either a list of closely related past, present, and reasonably foreseeable future projects, or a summary of projections contained in an adopted planning document which is designed to evaluate regional or area-wide conditions. This section further requires that the analysis include a discussion of projects under review by the lead agency and projects under review by other relevant public agencies, using reasonable efforts to discover, disclose, and discuss other related projects.

LEAs are the best source of information about similar projects which should be included in an analysis of cumulative impacts. When consulting with a lead agency please share information on solid waste projects which may reasonably have the potential to create or to exacerbate environmental impacts associated with the proposed project. When acting as lead agency, please coordinate with other sources such as governmental agencies, concerned citizens and organizations, or consultants for assistance in identifying issues or activities which may affect or be affected by the proposed project. CEQA Guidelines and CIWMB staff encourage early consultation as a means to avert potential problems, delays, or controversy early in the review process.

Please contact Sue O'Leary of my staff if you have any questions regarding this issue.


Original signed by:

Deputy Director
Permitting & Enforcement Division

Publication #232-97-004

The intent of the advisories is to provide guidance to Local Enforcement Agencies (LEA) in performing their duties. Guidance, for this purpose, is defined as providing explanation of the Board’s regulations and statutes.

Unless included by reference in the LEA's Enforcement Program Plan (EPP), advisories are not enforceable in the same manner as regulations because they have not been adopted through the formal rulemaking process (see Government Code sections 11340.5 and 11342.6). Advisories do not take precedence over statute or regulation.

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Martin Perez: Martin Perez (916) 323-0834