The California Environmental Quality Act (CEQA) is a powerful tool that can be used by the public to enforce large project to consider the environmental impact. The process starts when a Public Agency recognizes a large project and determines that it could potentially have an environmental impact. The Agency then conducts a study determining whether the impact is significant or not. If the Agency finds a significant impact, it then files an Environmental Impact Report (EIR), outlining all of the impacts and possible alternatives to avoid them. If the Agency does not determine a significant environmental impact, it files a Negative Declaration. During both outcomes, the Agency notifies the public of its findings, which allows the public to submit comments. By actively participating in the public comment process, you can become a CEQA advocate and help encourage agencies to properly consider the environment.

How to be an effective CEQA advocate

Step 1. Understand the terms commonly used in CEQA documents

  • CatEx – Categorical Exemption
  • CEQA – California Environmental Quality Act
  • DEIR – Draft Environmental Impact Report
  • EIR – Environmental Impact Report
  • MEIR – Master Environmental Impact Report
  • MND – Mitigated Negative Declaration
  • ND – Negative Declaration
  • NOD – Notice of Determination
  • NOE – Notice of Exemption
  • NOP – Notice of Preparation
  • OPR – Governor’s Office of Planning and Research
  • RDEIR – Recirculated Draft Environmental Impact Report
  • SLAPP – Strategic Lawsuits Against Public Participation
  • SOC – Statement of Overriding Considerations

Step 2. Know what questions to ask when reviewing the EIR

  1. What are the projects significant unavoidable impacts?
  2. Do the alternatives addressed in the EIR deal with those impacts?
  3. What significance thresholds are used for each impact category?
  4. Do the significant thresholds reflect adopted local policies and/or criteria established by a regulatory agency?
  5. Does the EIR gauge potential impacts against existing physical conditions?
  6. Does the EIR address all of the environmental topics relevant to the proposed project?
  7. Does the technical information provided in the EIR support the document’s findings?
  8. Did the EIR include discussion of environmental issues raised during the scoping phase and in responses to the Notice of Preparation?
  9. Does the EIR adequately define the resources that might be impacted?
  10. Does the EIR provide a clear line of reasoning in its conclusions related to impacts, their level of significance or non-significance, and the level of mitigation that would be achieved by proposed mitigations measures?
  11. Does the EIR’s statement of project objective allow for a reasonable range of alternatives?

Step 3. Identify any possible issues in the EIR

Once you have read and understood the CEQA document in question, it is time to come up with a thoughtful public comment. The goal of the public comment is to convey any concerns you have with the CEQA document in a calm yet persuasive manner. The key step would be to identify any potential issues or gaps in the environmental impact assessment in order to prove in your comment that the CEQA investigation has not been done properly. PCL has provided a list of questions one should ask to better understand the specific impacts each category will have on the local community and to identify any missing areas in an Environmental Impact Report. Keep in mind that these lists of questions are non-exhaustive and only represent a general, non-specific overview of potential impacts.

Environmental Impact Categories Include:


  • Consistency with the community’s design?
  • Tree removal and aesthetic impacts? (e.g. is there a tree ordinance)
  • Scenic vistas and resources?
  • Night lighting?
  • Visual character?
  • Overall site quality?

Agricultural Resources

  • Conflict with zoning or a Williamson Act contract?
  • Conversion of farmland to non-farmland uses?
  • Do changes lead to future farmland conversion?

Air Quality

  • Greenhouse gas inventory?
  • Air Quality Management Plan met?
  • Emission of NOx, PM10, PM2.5?
  • CO2 neutral?
  • Dust/Diesel Impacts?
  • Health Risk Assessment?
  • Acute/Chronic Impacts?

Biological Resources

  • Existing wildlife movement corridor?
  • Endangered, threatened or species of special concern?
  • Critical habitat?
  • Sensitive habitat?
  • Dept. of Fish and Game comments?

Cultural Resources

  • Native American artifacts present?
  • Are historic structures present?
  • Does the site have value to Native American Councils?
  • Native American Heritage Commission comments?

Geology/Soils (Geotechnical Hazards)

  • Earthquake faults?
  • Known/historic landslides?
  • Potential location for liquefaction?
  • Are landforms altered?

Hazards & Hazardous Materials

  • Site contaminants?
  • Exposure to regular pesticide use?
  • Dept. of Toxic Substances Control cleanup?

Hydrology/Water Quality

  • Water restrictions with drought?
  • Reclaimed water system?
  • Runoff Management Plan?
  • Low Impact Development?
  • Water supply assessment?
  • Is the water neutral?

Land Use/Planning

  • General Plan consistency?
  • Sustainable planning measures?
  • Distance from services?
  • Pre-wired/plumbed for solar?
  • Any zoning changes?

Mineral Resources

  • Loss of availability of known resources?
  • Loss of availability of access to known mineral recovery?


  • On-site noise levels?
  • Community noise level standards in the general plan?
  • Noise from construction?
  • Sensitive receptors?
  • Noise from daily operations?


  • Meets Regional Housing Needs Assessment (RHNA) goals?
  • Any Impact on local schools and community centers?
  • is there a balance between jobs and housing?

Public Services

  • Increases the urban-wildland interface?
  • Impacts to response times for emergency services?
  • In-lieu fees?
  • Availability of sewers, electricity, and utilities?


  • Are recreational facilities included?
  • Will recreational facilities be sufficient?


  • Changes to the level of service, load, and capacity for existing roads?
  • Additional traffic signals?
  • Reduce the use of vehicular transportation?
  • Transit Oriented Development?

Utilities/Service Systems

  • Underground electrical lines?
  • Upgrade to sewer or water/wastewater lines?
  • Opportunities for renewable power?

Mandatory Findings of Significance

  • ‘Cumulatively Considered’ impacts?
  • Potential environmental degradation?
  • Any potential impact on all species?

Becoming a CEQA Advocate Pt. 2

Click here to read PCL’s documents on CEQA.