Before you write a comment letter, make sure you’ve gathered the information you need. Most project documents are posted to CEQAnet.opr.ca.gov and/or on the lead agency’s website (see Finding CEQA Projects). If you cannot find the necessary documents, call or email the lead agency to confirm how to access them.  

The following guidance focuses primarily on the EIR, but most of it should still be applicable to writing comment letters for other CEQA forms of review, such as a Negative Declaration (see Public Review Periods). 

There are the three main forms of CEQA document review for which you can submit comments. 

  • Negative Declaration / Mitigated Negative Declaration – These comments will be based on the shortcomings of the analysis, which determined the project to have no significant impacts, or no impacts with mitigations. If you believe the agency failed to identify a significant impact, the comments should describe the impact and explain why it is potentially significant. Other comments could argue that mitigation would be ineffective or insufficient to reduce impacts to less than significant. 
  • Notice of Preparation (NOP) – Responding to the NOP, you’ll provide basic scoping comments to address concerns like sensitive natural habitat or rare plant populations that need to be evaluated for potential impacts in the EIR. If possible, include research that describes how a project could impact a resource or special management considerations for a resource.  
  • Environmental Impact Report (EIR) – The EIR comments comprehensively address all issues and gaps of the project’s environmental review. These comments “focus on the sufficiency of the document in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated.” (CEQA § 15204 (a)) 

Analyzing the EIR 

Once you have the EIR document, check the dates. Make sure the comment period is still open and that you have enough time to write a comment letter. 

To begin your analysis, start with the Table of Contents. EIRs can be thousands of pages long, so it is critical to strategize you research. Use the Table of Contents to find sections of the EIR related to your concerns. Common areas of focus for CNPS include biological resources, greenhouse gas emissions, and wildfire related impacts.

Using the Table of Contents, go through the document to find common locations for errors, such as the following:

  • Maps – Check that they are accurate, and that they match the text. 
  • Tables and graphs – Check the data against each other, against the text, and against the conclusions. 
  • Plant species and plant communities – Check the results of plant surveys, including the full list of taxa encountered and rare taxa documented. Make sure they report the survey methodology used and that it conforms to protocols published by the California Department of Fish and Wildlife.
  • Mitigation – Check that the mitigation is adequate, is not deferred, includes a restoration plan (if needed), and uses appropriate mitigation ratios. 
  • Monitoring – Check for pre-construction, construction, and mitigation monitoring. Check to make sure the monitoring plans are adequate and explicit. 
  • Alternatives – Check that the alternatives provide sufficient information or analysis, include a “no project” alternative, identify a “Environmentally Superior” alternative, and that they include reasonable alternatives with an explanation for those that were dismissed. You can propose other alternatives in your comment letter. 

For a thorough look at how to analyze an EIR, see Navigating the EIR.