Environmental Review Process

Tips on Providing Effective Comments to the Draft EIR

Environmental Impact Reports, or EIRs, can be imposing and complicated documents. They are, however, the primary way that the public has of understanding and assessing the potential environmental impacts of proposed development. An important part of the EIR process is the public review period for a Draft EIR. During this period the public is invited to make comments on the Draft EIR. The lead agencies are then required to provide responses to these comments and incorporate them into the Final EIR in the “Response To Comments” section.

Providing effective comments is, therefore, one of the most important ways that the public has to potentially effect change in a proposed project and to help generate a fully informed final document. These guidelines have been provided to assist you in preparing comments on the proposed scwd2 Regional Seawater Desalination Project so that you may participate in the process in a meaningful way.

  • Comments should focus on the adequacy of the Draft EIR, especially related to the following key elements:
    • Objectives of the project, including underlying purpose of the proposed project
    • Project description
    • Assessment of the environmental impacts
    • Setting
    • Significance thresholds
    • Methods of analysis
    • Conclusions and basis of conclusions
    • Proposed mitigation measures
    • Alternatives considered in detail and alternatives eliminated
  • Objectively evaluate the proposed project, impact conclusions, mitigation measures and alternatives, and be as specific and factual as possible in your comments.
  • Whenever possible, present facts or expert opinions. If not, provide personal experience or your personal observations. Comments that reflect only an emotional opinion will not be addressed in detail. For example, a comment that states, “I don’t like the project,” typically results in a response of “Comment Noted.”
  • Focus on the sufficiency of the Draft EIR in identifying and analyzing the possible impacts of the project on the environment. If you believe an impact has not been adequately identified or characterized, then:
  • Identify the specific impact in question;
  • Explain the nature of your comment or question on the impact and what aspect of the analysis your comment relates to
  • Explain why you would recommend changes or need additional information on the analysis conclusions, mitigation measures, or other element of the analysis and support your recommendations.
  • Include suggestions for improving the proposed project or offer specific alternatives and describe how they meet the objectives of the proposed project.
  • If your comments relate to the existing alternatives discussion, be specific about what aspect of the analysis you have questions or comments about.
  • Separate your concerns into clearly identifiable paragraphs or headings and keep a tight focus on each separate issue.
  • Include a valid name and address on your comment. Submit it before the deadline. Keep a copy of your comments for your records. Organizations should include the name of a contact person.
  • If submitting handwritten comments, please write legibly.
  • Be aware that, when responding to comments, the City and District need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.

Written comments can be submitted until 5PM, August 12, 2013 to:

Heidi Luckenbach, scwd2 Desalination Program Coordinator
City of Santa Cruz, Water Department
212 Locust Street, Suite C
Santa Cruz, CA 95060
Email: hluckenbach@cityofsantacruz.com

For more information on the EIR process, click here.


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