A program EIR (PEIR) is prepared when there is a series of related actions, generally involving the issuance of rules, regulations, and other planning criteria. It is usually bound geographically, such as by county and are often used for general plans or multi-phase projects. If a new project is not entirely considered in the scope of the program EIR, a new Initial Study, and its subsequent reports, must be prepared. The new documents can “tier” from the program EIR, referencing areas like the environmental setting and cumulative impacts, therein reducing the need for paperwork and redundancy.  

A program EIR will have comment periods similar to standard EIRs. A draft PEIR will be published for public comment, followed by the publication of a final program EIR and another round of public comment. If a person or group believes that the program EIR was approved improperly, they can sue for violations of CEQA. If smaller projects tiered off of a program EIR will not have environmental impacts, the smaller projects can proceed without additional CEQA review. If the smaller project will have effects that were not analyzed in the program EIR, additional CEQA review is required, often in the form of a subsequent or supplemental EIR.  

Key distinctions 

  • Conservation advocacy on program EIRs take a long-term approach, influencing present and future project developments. 
  • A PEIR allows the lead agency to consider cumulative impacts and mitigation strategies at a policy level early on, ensuring that these are not missed when judged on a case-by-case basis 
  • When a project uses a program EIR without developing an Initial Study or a project EIR, the program EIR must sufficiently address all of the project’s potential environmental impacts. Any activity must be considered fully within the scope of the full PEIR
  • The agency should use a written checklist to evaluate the site and the activity to determine whether the environmental effects are within the scope of the program EIR, if the later activity involves site specific operations 
  • When preparing subsequent EIRs and other new environmental documents, the program EIR can be used as an Initial Study or for reference. 


The California Vegetation Treatment Program (CalVTP) is a prime example of a statewide, far-reaching project that was approved with a PEIR. The CalVTP is a program designed to address California’s wildfire crisis through implementation of various treatments (prescribed fire, mechanical treatments, etc.) across 500,000 acres of land annually. The California Board of Forestry and Fire Protection, the lead agency in charge of approving the CalVTP, prepared the PEIR to evaluate the environmental impacts of the program as mandated by CEQA. 

Project proponents can use the VTP PEIR for CEQA compliance for their individual fuel management projects. Site-specific environmental analyses for the individual VTP projects are completed as Project Specific Analyses (PSAs). There is no public comment period associated with PSA, and as long as the project is within the scope of the PEIR, meaning the proposed treatments and their impacts were covered in the PEIR, no additional CEQA documentation or environmental review is needed. 

For more information on the CalVTP, please see the CalVTP overview document.