HOW TO COMMENT ON THE INITIAL STUDY

So you know you want to respond to the Initial Study on the Wonder Inn proposal and request an EIR by February 22.  You have a couple options:

  1. Use our click-and-send comment letter with an option to include additional comments of your own.  
  2. Create your own comment and send it in yourself.

If you’ve decided you want to create comments of your own, how do you do that and be most effective?

Your Goal:  a comment that:

  • Points out to County Land Use Services that the current Initial Study has not done an adequate job analyzing the potential significant impacts the Wonder Inn project could have on our community and resources.
  • Asserts that a full study is needed in the form of an Environmental Impact Report (EIR). 
  • States your specific concerns and supports those concerns with examples of ways in which you believe the study is inaccurate or incomplete.

How do you get to that goal?

  1. First, review the tips below for commenting.
  2. Second, dig into the Initial Study itself – either the whole thing, or just those elements that interest you, such as Air Quality, Hydrology, Biological Resources, etc.

TIPS AND HELPFUL INFO

Substance is everything:

  • Substance is required in the Initial Study phase, not emotion.  A comment of “I don’t like it!” doesn’t carry as much weight as a comment such as “I have lung/health issues and live a mile from this location. They plan to scrape away the existing vegetation which will create more PM10’s in the air.”
  • The 2022 CEQA Statute and Guidelines lays it out (p. 181):
    • What counts is substantial evidence.  “Substantial evidence shall include facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts.”
    • What doesn’t count: “Argument, speculation, unsubstantiated opinion or narrative, or evidence that is clearly inaccurate or erroneous, or evidence that is not credible, shall not constitute substantial evidence.”
  • Does this mean only expert opinion matters?  No, your experience and observation as a resident or visitor can be valid and important too, but your remarks need to be specific and substantive.

 Burden of proof:

  • The burden of proof is on the county and the developers in this phase, not us.  We don’t need to do their research for them. Our job is to raise substantive questions and concerns.  That said, if you can access reports that contradict the claims of the Initial Study, it’s fine to include that with your comment.

What happens with your comments?  Can the County just ignore them?

  • Following the comment period County Land Use Services will issue a recommendation in which they must respond to each substantive comment submitted to them. (This is why substance matters!)

Standing:

  • It helps in your comment to establish your “standing”:  What is your investment in the community?  Are you a resident or home/property/business owner?  For how long?  Are you a visitor?  If so, what about Wonder Valley attracts you?  What brings you to this place and is not replaceable? 
  • Do you have to be an expert?  No.  But if you have particular expertise or experience you may be able to add expert opinion and/or identify points of relevant concern.  In that case, give your relevant education or work experience and/or use titles or credentials.  This can strengthen your comments.

Repeated comments:

  • Did you already comment?  You may have submitted comments on the Wonder Inn proposal before, but the “Initial Study” is a specialized part of the process that needs its own commenting. 
  • How many times should you comment?  One comment for this Initial Study phase may be enough:  Because only substantive comments in this phase will be effective, a single substantive comment is sufficient; multiples won’t increase your impact.  However, if you later decide there is another concern you need addressed, it’s fine to send in another.

What to include:

  • Images are good when relevant.  Example: photos of blowing dust.
  • Page or section numbers if you make a reference to a specific part of the Initial Study or Appendices. 
  • Citations – if you refer to an outside resource, study, news article, etc., be sure to attach a copy of that reference or note where it can be found.

Where should you send it?

  • To Planner Azhar Khan, with copies to Supervisor Dawn Rowe, Planning Commissioner Michael Stoffel, and Field Representative Steve Reyes.  FIND THE ADDRESSES HERE.
  • Be sure to include Project Name and Number on your comment:  Wonder Inn Hotel/Resort (Twentynine Palms), PROJ-2021-00163.
  • Please cc a copy to Stop the Wonder Inn so we can track what issues have been entered into the process.  Thanks!

YOU’RE READY:  Now What?

Ready to take a look at the Initial Study itself?  Here it is, with our guide.