Residents need to submit Library EIR comments by May 7th

Dear Residents,

The 45-day comment period for the Library EIR ends on Monday, May 7th.  All comments submitted by 5:00 pm on that day have to be answered by the town and the Final EIR must include a copy of your letter and the town's answer.  If the answers provided are not adequate and the city council certifies that they are, then residents have a basis for appealing the council's decision.

Whether you are in favor of the proposed plan to build a much bigger library in Holbrook-Palmer Park (an areas zoned as Open Space) or against this plan, the only way to insure that the final implementation addresses the significant impacts you care about is to read the draft EIR and write your comments.  Any errors, inadequate analyses, misstatements of fact or omissions must be commented on before the 7th, for the town to have to address them.

If you are under the impression that the EIR is being done completely impartially, think again.  A quick glance at the "Contacts (p. 182)" cited by LSA, the consultants working on the EIR, show that the ONLY residents listed are Library Committee members, all of whom somehow knew to write to Neal Martin, Town Planner, between January and March with their thoughts about the project, which have subsequently been cited and factored into the draft EIR. That seems rather skewed and, in fact, the bias of that group is indeed reflected in the draft EIR.

The bad news is that writing an effective EIR Comment Letter takes some time and discipline. Simply complaining about the way the Library Committee handled the community engagement phase won't help change the project at all.  You must comment only on the facts as presented in the EIR, the analysis of the EIR and factual or significant omissions pertaining to significant environmental impacts (which may include: aethetics, biological resources, public services, cultural resources, hydrology, noise, recreation, air quality, land use/planning, population/housing, traffic and a few other areas).  A close and careful reading of the EIR and some critique of the facts and analysis provided there is what is appropriate. 

For a project of this significance to the town, there has been surprisingly little guidance for residents about the overall process or the impacts of the project going ahead as designed. The town has not made any extra hard copies of the EIR, which means that everyone who has an interest in seeing the EIR has to access the electronic version, which has been posted on the Town's website (in five separate .pdfs on the lower right side of the home page) as at: http://www.ci.atherton.ca.us. 

For a quick overview on how to provide effective comments, take a look at How to Comment on an EIR, from Greenbelt Alliance (http://www.greenbelt.org/advocacy/planning-for-change-how-to-comment-on-an-environmental-impact-report/).

For really good detailed and helpful information, go to the PCL Foundations website, and their publications called Get Familiar with CEQA.  There you can acess a number of the key forms that can help you understand the process, write a compelling comment letter, and learn when opportunities exist for public comment.  PCL's Community Guide to CEQA is considered the bible for community members who want to have an impact on how a project is done but it has to be ordered and it is a big volume.

A sample of a professional, hard-hitting EIR comment letter for a different project has been kindly provided to us as an example of the kind of letter that can be effective to force the town to address significant impacts. A letter crafted along this model, delineating each essential comment with supporting facts, can force the town to have to defend their responses at subsequent public hearings. We have attached it to this message for your edification.

After the Final EIR process has been certified, there is very little that can be done by residents to prevent a determined council majority from moving ahead with the project, no matter how unhappy residents are about it, unless those issues have been raised during this comment period.  If you have concerns about this project, you must submit those in the form of an EIR comment letter by Monday for the town to be required to address them.

(Note: The attached EIR Comment Letter has been made available in the Files area of the Athertonians website at: http://groups.yahoo.com/group/Athertonians, which you may access if you are a member of the Athertonians email list).