GUIDE TO THE INITIAL STUDY

THE COMMENT PERIOD FOR THE INITIAL STUDY ENDED ON FEBRUARY 22, 2023.  But it’s still worthwhile knowing what’s in the Initial Study.  It shows you exactly what the Wonder Inn developers have submitted to the County and how they officially envision their project and its effect on our environment.  So let’s take a look.

First thing to know:  The Initial Study is based on materials and studies that were submitted by the developer.

So what’s in it?

  • A summary of the developer’s application, with a description of the project: pp 1-11.
  • Required matter:  Consultation, evaluation format, and determination:  pp 12-14.
  • Review of CEQA elements (e.g., Aesthetics, Biological Resources, Air Quality, etc.): pp 15-88.
  • Mitigation measures:  pp 88-91.
  • References:  pp 91-92.

The Elements

The heart of the Initial Study is the review of the CEQA elements.  What’s a CEQA element?   An environmental factor that might potentially be impacted by the project.

The Initial Study reviews each of these elements to determine if the Project might be expected to cause significant impacts.  A required series of questions is asked, a determination of significance is made for each question, and then the County substantiates their determination.

Head-start:  Interested in a particular element?  You can get a head start by watching the presentations from our Jan 28 Informational Meeting; you’ll find the element you’re interested in indexed by segment.

Helpful to know:  The Initial Study/Mitigated Negative Declaration volume is 92 pages BUT it’s accompanied by a volume of appendices (895 pages) that contains the studies the determinations are based on. Both volumes are part of the Initial Study and subject to your review and comment.

YOUR JOB:

Review the elements that are of interest to you.  They occur in alphabetical order.

  • In each element, first you’ll see a list of questions (a, b c…) that are required by CEQA law.
  • Next to each question are checkboxes, where County planners have determined whether a significant impact is expected relative to that question.
  • Following the list of questions is a list of answers:  the Substantiation. Here the planners support their determinations based on materials and studies the developer has submitted.

While reviewing the Substantiation, ask yourself these questions:

  1. Were your specific concerns not included?
  2. Were your concerns brought up but only partially addressed?
  3. Is the information provided incorrect, or is it insufficient to make a reasonable determination?

Finally, put it all together:

If you answered yes to any of those three questions, that’s the beginning of your comment. Identify those deficiencies and ask LUS why that information is not included or is inaccurate.  Make clear that the wrong or missing information is essential for making a judgment as to potential significant impacts of the Project.  Provide any personal or technical information you think supports your point.  Most importantly, state that in order to make an adequate determination of significant impacts these issues must be addressed with further study and that a full EIR must be completed.  Do all of this keeping our commenting tips in mind, sign it, and send it in!  UPDATE:  COMMENT PERIOD HAS ENDED.

Want to see an example?  See the Response Comments submitted by Stop the Wonder Inn Project.  But don’t think you need to submit 187 pages!  One page can do just as well.  And if you look in that response you’ll see many styles and approaches. There’s room for every voice.

BONUS Info and Resources:

  • Find all the Initial Study documents, County documents, and other links on our Resources page.
  • The full name of the study is “Initial Study/Mitigated Negative Declaration”.  What does “Mitigated Negative Declaration” mean?  The County planners have declared that the Project will have no significant impacts that cannot be mitigated – “mitigated” meaning tweaks to the proposal such that any potential impacts would be reduced below the level of significance.
  • The Initial Study process is part of CEQA – the California Environmental Quality Act.  CEQA is a transparency law, requiring potential environmental impacts to be revealed to the public before a project gets approved.  We have more resources about CEQA on our Resources page, including CEQA 101, a PowerPoint by Pat Flanagan.  We also have a link to the full 2022 CEQA Statutes and Guidelines.
  • Also of help on our Resources page: