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L <br /> CEQA requires that an EIR be prepared with a sufficient degree of analysis to <br /> provide decision-makers with information that enables them to make an informed <br /> decision regarding environmental consequences. (CEQA Section 15151.) For <br /> example, in Concerned Citizens of Costa Mesa, Inc. v. 32nd District Agricultural Assoc. <br /> (1986)42 Cal. 3d 929, the court held that"the EIR must contain facts and analysis, <br /> L not just the agency's bare conclusions or opinions." Here, the EIR contains <br /> conclusions and opinions but lacks a demonstration of its analysis. Thus, the B-5 <br /> conclusions presented in the Draft EIR's air quality analysis in Section 4.6 are <br /> ` unsupported and deprive the public of the opportunity for proper review. In light of <br /> the inadequacies and erroneous conclusions regarding impacts on air quality from <br /> both Project construction and operations outlined in the comments below, this <br /> omission is troublesome. The Draft EIR should be revised to contain sufficient <br /> . information for a reviewer to verify the presented results and be recirculated for <br /> 'r public review. <br /> The County was first asked on June 6, 2006 to make the above information <br /> L' available for review.2 After repeated e-mails, a letter, and phone requests to the <br /> County, Environmental Science Associates ("ESA"), the EIR preparer, made the <br /> 6. electronic files available for review on June 21, 2006. These spreadsheets contain <br /> supporting calculations for Project construction and operation emissions. These B-6 <br /> spreadsheets are attached hereto in their native format as Exhibit 1. These <br /> spreadsheets contain critical information about the Project and the emission <br /> estimates that could not have been discovered otherwise. Further, they indicate that <br /> that many errors were made in estimating Project emissions. <br /> These spreadsheets should have been included in an appendix to the Draft <br /> EIR and should have been made available at the time the Draft EER was released. <br /> Because the material in these spreadsheets is very complex and poorly organized <br /> and annotated (no summary tables indicating how the emissions in the Draft EIWs B-7 <br /> Table 4.6-5 were derived, missing or incorrect row and column headings, missing or <br /> incorrect units of measure throughout), the absence of this information in a timely <br /> manner seriously impaired our ability to thoroughly review it. (See Comment III.) <br /> Thus, we reserve our right to supplement these comments. <br /> L <br /> L2 John Williams,Williams Research,Email to Chandler Martin,San Joaquin County, <br /> Re:RMC Information Request,June 6,2006. <br /> L <br /> 3 <br /> L <br />