and directed to the public with full understanding that many (and probably most) commenters are not professionals in the relevant disciplines of environmental analysis, and will justifiably expect reasoned, intelligent responses that draw reasonable inferences from the comments, and that sensibly connect the import and evidence provided by comments with conditions and impacts toward which they are directed. Evasion and obscuring of the evident significance and meaning of public comments, or of the evidence supporting them, is not warranted by CEQA in any way. Yet such evasion and obscuring is a central of the FEIR responses to comments on traffic. CVA’s The FEIR responses to CVA comments on the traffic conditions in the violate CEQA, and because many of project’s vicinity CVA’s comments refer directly to violations of CVMP and General Plan provisions, certain of the FEIR responses also effectively promote or advocate violation of the own plans and ordinances. County’s As a result, this FEIR must not be certified: CEQA Guidelines require that to approving a project the lead agency (emphases ours) “Prior shall certify that: (1) The final EIR has been completed in compliance with CEQA; (2) the decision-making body reviewed … and considered the information contained in the final EIR prior to approving the project; and (3) the final EIR reflects the lead agency’s independent judgment and analysis.” (CEQA Guidelines §15090.) An EIR that is not complete, not adequate, and which demonstrates lack of good faith effort at full disclosure (all of which are shown in the comments to be present in this FEIR) is not in “completed compliance with and cannot be certified under CEQA. CEQA” According to CEQA of Guidelines’ discussion certification, “the decision body itself must consider the information in the EIR.” Some specific examples of the problems in the EIR:
and directed to the public with full understanding that many (and probably most) commenters are not professionals in the relevant disciplines of environmental analysis, and will justifiably expect reasoned, intelligent responses that draw reasonable inferences from the comments, and that sensibly connect the import and evidence provided by comments with conditions and impacts toward which they are directed. Evasion and obscuring of the evident significance and meaning of public comments, or of the evidence supporting them, is not warranted by CEQA in any way. Yet such evasion and obscuring is a central of the FEIR responses to CVA’s comments on traffic. The FEIR responses to CVA comments on the traffic conditions in the project’s vicinity violate CEQA, and because many of CVA’s comments refer directly to violations of CVMP and General Plan provisions, certain of the FEIR responses also effectively promote or advocate violation of the County’s own plans and ordinances. As a result, this FEIR must not be certified: CEQA Guidelines require that (emphases ours) “Prior to approving a project the lead agency shall certify that: (1) The final EIR has been completed in compliance with CEQA; (2) … the decision-making body reviewed and considered the information contained in the final EIR prior to approving the project; and (3) the final EIR reflects the lead agency’s independent judgment and analysis.” (CEQA Guidelines §15090.) An EIR that is not complete, not adequate, and which demonstrates lack of good faith effort at full disclosure (all of which are shown in the comments to be present in this FEIR) is not “completed in compliance with CEQA” and cannot be certified under CEQA. According to CEQA Guidelines’ discussion of certification, “the decision body itself must consider the information in the EIR.” Some specific examples of the problems in the EIR: