What is a comment letter?

Written comment letters are an important way to make your voice heard in the CEQA process. They are fact-based letters that help public agencies conduct proper review. They are not based on opinions or personal judgements of projects. Rather, they offer a critical response to the analysis performed by the lead agency, and the conclusions they find.  

CEQA’s purpose is to ensure that governmental bodies make informed decisions about the environmental effects of projects before approving them. The public is the backbone of the CEQA process that holds lead agencies accountable for CEQA compliance. Comment letters give the public the power to point out where lead agencies are falling short of CEQA requirements and how the environmental review and analysis can be improved.  

The Goal of the Letter 

There are two main reasons for submitting a comment letter: 

  • Identify deficienciesComments can identify flaws or deficiencies in project design, the agency’s analysis of environmental impacts (e.g. if the agency’s analysis has gaps or is omitting key information or data), the agency’s conclusion about whether an impact is significant, and how it intends to mitigate significant environmental impacts. The hope is that agencies will be responsive to comments and work to fix the issues raised. By law they are required to consider and respond to timely received comments on the EIR, but this doesn’t always mean that they will improve the project, which leads us to the next point. 
  • Gain Legal Standing Submitting a comment letter at any time before project approval establishes legal “standing” for the author. Having standing to file a lawsuit on the project gives us the right to take legal action after the project is approved. Without it, we could not participate in legal action. CNPS treats lawsuits as a last resort. Litigation is an important tool that is often needed when all other tools to stop or improve a harmful project have failed. Only issues that were raised in the comments or at public hearing during the CEQA process can be raised in the lawsuit, so it is important that comment letters mentions each issue that may need to be raised in a lawsuit. 

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