Section 15332 - In-Fill Development Projects. to projects with no significant environmental effect (see below). Document signatures by the Project Manager and the District/Region Senior Environmental Each notice shall remain posted for a The City Council shall act on the CEQA appeal within 75 days after the expiration of the appeal period or within any additional period mutually agreed upon by the applicant and the City Council. The actions are exempt under the common sense exemption in State CEQA Guidelines 15061, subdivision (b)(3) because it can be seen with certainty that there is no possibility that the actions may have a significant effect on the environment. of an historical resource. or commuter service on high-occupancy vehicle lanes already in use, Activity is exempt from the CEQA because it is not a project as defined in Section 15378. In order to help improve the reliability of its imported water supply, CVWD agreed to participate with the State Department of Water Resources (DWR) development of the Delta Conveyance Project in 2020. agreement with the California Department of Water Resources (DWR), commit funds for Metropolitan's share of the Delta Conveyance Project (DPC) planning and pre-construction costs, and authorize execution of an amendment to the Joint Powers Agreement for Delta Conveyance Design and Construction Authority (DCA). 0 ]Qov3Ef^R%TAo*h x[QQ @s,a>P0h*]`eUc. _8>/euzZ.I1 rwL8HC#^. Projects to maintain, repair, restore, demolish, or replace property This document is not available on Westlaw. (CEQA Guidelines 15126.2(c), see also Pub. endstream endobj startxref Notes This definition ensures that the action reviewed under CEQA is not the approval itself but the development or other activities that will result from the approval. None of the exceptions to the use of the common sense exemption as identified in State CEQA Guidelines 15300.2 exist with the recommended actions, Copyright Whether an entity is a public agency is a question of statutory interpretation, subject to de novo review. Coachella Valley Water District 99 0 obj <> endobj If, upon this preliminary project determination, "the proposed activity is found not to be a project, the agency may proceed without further regard to CEQA." (Citing Muzzy Ranch, at 380; CEQA Guidelines, 15060(c)(3).) PreliminaryReview Therequired CEQA review process can result in three different determination/document typesan or facilities damaged or destroyed as a result of a disaster in a 15378 - Project California Codes of Regulation| 15378 - Project (a) "Project" means the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment, and that is any of the following: A "project" refers to the whole of an action that has the potential to cause a physical change to the environment The proposed action of adopting the temporary Colorado River water Conservation Agreement with BOR in 2022 is exempt under the provisions of CEQA and the State CEQA Guidelines. C. . Information on the regulations implementing the California Environmental Quality Act (CEQA). ". ), Hon. Disclose public agency decisions. Section 3. 1. Next . 1G@oi0Zl>:m|x%smD\Y!$7qJDmJo6xs7 You can always see your envelopes Legal Analysis Current through Register 2022 Notice Reg. The CPUC reviews permit applications under two concurrent processes: (1) an environmental review pursuant to the California Environmental Quality Act (CEQA), and (2) the review of project need and costs pursuant to Public Utilities Code (PU Code) sections 1001 et seq. See the definition of "approval" in Section 15352. The State CEQA Guidelines: These are the CEQA regulations and are labeled "guidelines" because they contain many advisory and permissive interpretations in addition to mandatory requirements. 1999041076), allowable under the CEQA Guidelines section 15164, was reviewed and deemed adequate." . If the project is determined to be categorically exempt, Caltrans must consider whether the exemption is negated by an exception pursuant to CEQA Guidelines, Section 15300.2, and Public Resources Code, Section 21084. California Resources Agency (2002) 103 Cal.App.4th Section 21080 of the Public Resources Code exempts from the application of CEQA those projects over which public agencies exercise only ministerial authority. environment be significant. place will result in cumulative impacts; There are "unusual circumstances" or landslide, provided that the project is within the existing Right-of-Way ]=az|)=W@{~ 6. (See Picayune Rancheria, supra, 229 Cal.App.4th at p. An emergency exemption under CEQA does not necessarily remove Caltrans responsibility to comply with other state laws nor does it have any bearing on compliance with federal laws. We have notified your account executive who will contact you shortly. Your subscription has successfully been upgraded. that a project on the State Highway System is exempt from CEQA and has signed the CE/CE form, a Notice of Exemption (NOE) must be filed with the SCH. amendment of Note filed 10-26-98; operative 10-26-98 pursuant to Public Resources In the alternative, and even if the proposed action was a project under CEQA, the action is categorically exempt under the provisions of CEQA and the State CEQA Guidelines. For more information on the specific proposal to update the CEQA Guideline addressing transportation analyses, visit Transportation Impacts (SB 743). Ventura County (1975) 51 Cal.App.3d 648; and Communities for a Better Environment v. %%EOF CEQA Guidelines 15378). Additionally, the Air District is working with the California Air . Christine Asiata Rodriguez, is the Manager of the State Clearinghouse (SCH) at the Governors Office of Planning and Research (OPR). 132 0 obj <>/Filter/FlateDecode/ID[<77DEEF012D5FF742BC0D017986EA08D2>]/Index[99 61]/Info 98 0 R/Length 142/Prev 202876/Root 100 0 R/Size 160/Type/XRef/W[1 3 1]>>stream 44). "Emergency" includes such occurrences as fire, flood, earthquake, or other soil or geologic movements, as well as such occurrences as riot, accident, or sabotage." Prevent or minimize damage to the environment through . You may also contact the OPR via email at state.clearinghouse@opr.ca.gov or via phone at (916) 445-0613. Download . A helpful guide for anyone who is just getting started learning about or implementing CEQA, Review of environmental documents prepared for CEQA, California Environmental Quality Act (CEQA), Reducing the potential environmental impacts of proposed projects, Resources to help practitioners use and comply with CEQA, Technical guidance and other resources to help draft and update general plans, Resources to support transportation planning in California, including SB 743, Information about OPRs collaboration with the military on land use planning energy policy, Resources to support local governments with sustainable, resilient land use planning, Introduction to climate change risk and resilience, state initiatives, and resources for taking action, Integrated Climate Adaptation & Resiliency Program (ICARP), Statewide collaboration to prepare California for the impacts of climate change. to the local agency with a notation of the period it was posted. CEQA 21065 Guidelines 15378 Project Description: Guidelines 15124 Public Review Period For Substitute Environmental Documentation, Negative Declarations CEQA 21091 Recirculation Release of revised environmental documentation for public reviewwhen significant new information is added after public Were the actions to be considered a CEQA project, these actions would be statutorily exempt from environmental review pursuant to State CEQA Guideline 15262 because the actions merely call for the funding and completion of feasibility and planning studies, not including the completion of CEQA review itself. 15378(b)(2) of the State CEQA Guidelines). (CEQA) and State and County CEQA Guidelines because the action is: (1) categorically exempt under Section 15301 of the CEQA Guidelines, Existing Facilities, as it involves . As of October 3, 2022, surface water elevation of Lake Powell was 3,529.51 ft (25% of capacity) and Lake Mead was 1,045.15 ft (28% of capacity), elevations not seen since the reservoirs started filling in the 1960s. try clicking the minimize button instead. Caltrans is the lead agency for its own projects. Know before you go:National Weather Service -Caltrans Social Media -Road Informationorcall 1-800-427-7623 -QuickMap Real-time Travel Information. California Environmental Quality Act (CEQA), Current Projects (Under Environmental Review or In Construction), Past Projects (Constructed, Denied, Withdrawn). It is estimated that the contribution volume will be approximately 10,000 acre feet (af). endstream endobj startxref 1280 0 obj <> endobj A lead agency is the public agency that has the principal responsibility for carrying out or approving a project. 5. Posted in , , CEQA Guidelines, , Land Use, Litigation, Mitigation, Project Description, Standard of Review, Water Supply. endstream endobj startxref CEQA also does not apply to projects which do not cause a direct or reasonably foreseeableindirect change to the physical environment(see CEQA Guidelines 15378 for further guidance on whether an action constitutes a project). hbbd``b`oA $@Jz"2@ 2) Approve Amendment to the Class 8 Member Agencies Election Procedures for Delta Conveyance Authority Board of Directors Section 15378 of the CEQA Guidelines provides the following definition of a project: (a) "Project" means the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in CEQA Guidelines 15378 interprets a "project" to be made up of two distinct elements: (1) an activity undertaken by a public agency, that (2) has an actual or potential to cause a change to the . and General Order (G.O.) A "project" refers to the whole of an action that has the potential to cause a physical change to the environment (direct or indirect), and requires discretionary action from the public agency (exercises its judgment in deciding whether and how to approve or carry out a project ). . Discretionary or Ministerial . The project and successive projects of the same type in the same 1. Furthermore, where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA (Section 1506l(b)(3) of the State CEQA Guidelines). and resource evaluation activities needed for the environmental review and permitting do not result in any adverse impacts to an environmental resource. Since ministerial projects are already exempt, As such, the actions recommended herein are not a project requiring environmental review under CEQA pursuant to State CEQA Guideline 15378, subdivisions (a2) and (b)(2), (b)(4), and (b)(5). Section 15168 - Program EIR (a) General. A trustee agency means a state agency having jurisdiction by law over natural resources affected by a project that are held in trust for the people of the State of California. v. Morgan Hill Unified School District, (1992) 9 Cal.App.4th 464; and Fullerton 14, The CPUC maintains websites for both current projects and past projects: Investor-owned utilities are required to obtain a permit from the CPUC for construction of certain specified infrastructure listed under Public Utilities Code sections 1001. The filing of an NOE and the posting on the list of notices starts a 35-day statute of limitations period on legal challenges to the agency's decision that the project is exempt from CEQA. Categorical Exemption: State CEQA Guidelines 15301. The California Environmental Quality Act (CEQA), now more than 40 years old, is one of the state's most important environmental laws. guideway or busway public transit services; the development V. CITY OF MOORPARK, ET AL. (.U/ku3\s6v(X,d)xon9X+H(R9>R'j|f9Uusx^-=! XU; S=X;;2Aqf=%ybP(BP2v(u0: DAhz5 &t,&`HnU&8{WYZ\5qmE8t 521uO`QPk,{ The list of exemption classes begins at Section 15301 in the CEQA Guidelines. The California Department of Fish and Wildlife with regard to the fish and wildlife of the state, to designated rare or endangered native plants, and to game refuges, ecological reserves, and other areas administered by the department; The State Lands Commission with regard to state owned "sovereign" lands such as the beds of navigable waters and state school lands; The State Department of Parks and Recreation with regard to units of the State Park System; The University of California with regard to sites within the Natural Land and Water Reserves System. These classes are known as categorical exemptions. However, 24. 404 0 obj <>/Filter/FlateDecode/ID[<1CD5281495D4114EA650AF4EC2FFB83A>]/Index[385 34]/Info 384 0 R/Length 90/Prev 186517/Root 386 0 R/Size 419/Type/XRef/W[1 2 1]>>stream The Guidelines provide examples of projects undertaken directly by a public agency, such as "public works construction and . The entire rulemaking package filed with OAL on January 4, 2013, including the final adopted regulations, can be found here: Documents Uploaded During the . Trustee agencies include: Common examples of responsible agencies include: the Regional Water Quality Control Board for its Section 401 Water Quality Certification, the California Department of Fish and Wildlife for its Section 1602 Lake or Streambed Alteration Agreement, and the Office of Historic Preservation for its concurrence on affected cultural resources. Informal consultation and further environmental studies may need to be initiated with applicable resource agencies, such as the U.S. ], Guidance for Determining CEQA Lead Agency Status for Project on the State Highway System, Mandatory Filing of Notices of Exemption for Projects Subject to CEQA, Categorical Exemption/Categorical Exclusion (CE/CE) The action is not defined as a project under CEQA (Public Resources Code Section 21065, Section 15378 of the State CEQA Guidelines ) because neither the funding agreement and commitment of funds nor the JPA Amendment will cause either a direct physical change in the environment or a reasonably foreseeable indirect physical change in the environment and involves continuing administrative or . Document the use of the common sense exemption on the CE/CE form. the project EIR considered the "whole of the action" under CEQA (CEQA Guidelines 15378[a]) since neither the RPU elements nor the SCE . Projects which require specific actions necessary to prevent or mitigate an emergency, can qualify for an exemption under CEQA (CEQA Guidelines 15269). Authorize funding for CVWDs share of the environmental planning and preliminary design, and pre-constructions costs for 2021 and 2022, not to exceed $4,261,248; Environmental reviews are conducted pursuant to the California Environmental Quality Act (CEQA), where the CPUC is a lead or responsible agency, and as further specified by the CPUC's CEQA-related rules. To review the CEQA statute and the CEQA Guidelines in their entirety, please see the Association of Environmental Professionals electronic CEQA Guidelines book. First, it is an activity that may cause a direct (or If, upon this preliminary project determination, "the proposed activity is found not to be a project, the agency may proceed without further regard to CEQA." (Citing Muzzy Ranch, at 380; CEQA Guidelines, 15060(c)(3).) movement, or landslide. Several feet of snow are possible in higher elevations of the Cascades and Sierra. Consider: Motion to Adopt a Resolution Declaring Certain Properties as Exempt Surplus Land and Non Surplus Land, as Defined in Government Code 54221(b); and Authorizing the Filing of the Inventory List Establishing the Town's Inventory in Compliance with Government Code 54230(a)(1) Pursuant to CEQA Guidelines 15378 and 15061(b)(3). ), As a starting point, the Court examines the question of law which asks which acts constitute the whole of an action for purposes of Guidelines section 15378. (Tuolumne County, supra, 155 Cal.App.4th at 1224; see also Lighthouse, supra, 131 Cal.App.4th at 1208 (The prohibition against piecemeal review is the flip side of the requirement that the whole of a project be reviewed under CEQA.). The recommended actions do not constitute project approval by CVWD of the DCP, nor do the actions authorize or approve construction of the DCP. The establishment, modification, structuring, restructuring, or approval of rates, tolls, fares or other charges by the City of Los Angeles which the Decision-Making Body finds are for the purpose of: 6 The first step in determining whether a public agency action is subject to the provisions of CEQA is to determine whether the action is a "project," as defined by CEQA (PRC Section 21065 and CEQA Guidelines Section 15378). a "project" by CEQA (CEOA Guidelines 15378). (Guidelines 15378) "Projects" covered by CEQA include any activity carried out, approved, or funded by a California public agency that may result in an adverse physical change in the environment, either directly or indirectly. This broad definition is intended to avoid so-called "piecemeal" environmental review . Guidelines for the Implementation of the California Environmental Quality Act . &TYY8s8V-5U/b25v)_g+t`*c#Xa7TlHqYJCeQnXDA5 A4u~v"P+DF!W,Q>PmTE1%TAM){(2l(JnB]BeU !h#\A2YPS&\IBh^PgBA^~tEifmAg7VU6;r'xJUj R) [Dd2X n/ 'J qR(c|x8K?sw{C Zd1^2`mTT?9lJ6nS\cWve;kTr`~KLM@ W!u}u(%)vb?%%!l? Similarly, if more than one government agency must grant an approval, only one CEQA document should be prepared. {]jw16+a,'i Examples of the statutory exemptions that may apply to Caltrans activities include ministerial projects and emergency exemptions (see below); the establishment or modification of tolls; a project for the institution or increase Sections 15300 to 15333 . 2 Id. Upon completion of the review, the Project . CEQA Guidelines, 15378(b)(4). ICARP technical assistance, decision-support tools, guidance, and other adaptation and resilience resources. Change without regulatory %PDF-1.5 % 11343.4(d) 3. 1 CEQA Guidelines 15378(a). These actions are not CEQA. CEQA Guidelines, 15378(a) Reasons for Exemption. For more information, please visit OPRs Accessibility Site. This includes projects that will remove, destroy, or significantly including the modernization of existing stations and parking facilities; . Ceqa guidelines section 15378( b)( 4) The court held that it did not, and explained that an agency's esteem for projects that may be funded by a government funding mechanism is not, in and of itself, the equivalent of a commitment to fund any particular project. 30). Your content views addon has successfully been added. All separate permits and approvals for a particular project shall be considered together along with the underlying activity itself when determining the project's environmental Under the CEQA Guidelines, 15060(c)(3), an activity is not subject to CEQA if it is not a project as defined in Section 15378. Under CEQA, "projects" must be discretionary, public agency actions which have the potential of affecting the environment. when new changes related to " are available. Resources Code, 21065; CEQA Guidelines 15378(a) [both defining "project"].) No specific physical location. Below are resources for permit applicants and public parties interested in participating in CPUC's environmental review and/or the CPUC's economic and need assessment for a particular project. A responsible agency is any public agency other than Caltrans that has discretionary approval power over the project. Accordingly, the proposed action qualifies for a Class 6 Categorical Exemption (Section 15306 of the State CEQA Guidelines). subject to CEQA; however it is advisable that Caltrans includes documentation in the project file that offers evidence that the project is exempt by statute. . Caltrans documents its determination that a project meets the criteria of a categorical exemption by completing the CE/CE form and retaining it in the project file. section 100, title 1, California Code of Regulations (Register 2003, No. 1. Article 19. A participation level of 3.78% share associated with the Delta Conveyance Project; of Historic Preservation pursuant to Section 5028 (b) of Public Resources The California Natural Resources Agency, with assistance from OPR, completed a comprehensive update to the CEQA Guidelines in late 2018. Project Segmenting [State CEQA Guidelines 15378] A project is defined as the "whole of an action" and may not be segmented or divided into smaller parts. Substances Control and the Secretary of the Environmental Protection First, approval of the 2022 Agreement is not subject to CEQA because it does not constitute a "project," i.e., pursuant to State CEQA Guidelines 15378(a), the action has no potential to result in a direct or reasonably foreseeable indirect physical change in the environment because . A project is not a "project" under CEQA if it does not have "a flood, storm, earthquake, land subsidence, gradual earth movement, 1302 0 obj <>/Filter/FlateDecode/ID[<27730CE628381F44A127F3E7EA4BE6C7><926696184BD2D24C8A4EF83047993510>]/Index[1280 55]/Info 1279 0 R/Length 101/Prev 154529/Root 1281 0 R/Size 1335/Type/XRef/W[1 2 1]>>stream Whereas CEQA Guidelines section 15378 (b)(4) further provides that: "A project does not include . Amendment of subsection (a) Emergency repairs include those that require a reasonable amount of planning to address an anticipated emergency. Joint Union High School District v. State Board of Education, (1982) 32 Cal.3d 779; The Secretary for the California Natural Resources Agency has adopted CEQA Guidelines implementing Public Resources Code section 21094.5 and 21094.5.5 (SB 226 - Infill Streamlining). A "project" has two essential elements. will be able to access it on trellis. Amendment of subsection (CEQA Guidelines, 15378(b)(1), 15379.) Ministerial actions, by definition, are not "projects" because While conducting this review for completeness, the agency should be alert for environmental issues that might require . Resources Code 21080(a), (b)(1); CEQA Guideline 15357 & 15369.) Per CEQA Guideline 15378(a), the term "project" means the "whole of an action, which has the potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect change in the environment" (emphasis added). Code Regs. $$bP QD#+:pP9s>d` 5AQI. The local agency shall retain the notice for not less than 9 months. facilities; a project for the institution or increase of passenger DWR proposed the DCP and initiated the required California Environmental Quality Act environmental review in January 2020, and it has a contract with the DCA for engineering and design work needed to support that review and other pre-construction planning. v. City of San Jose, et al. CVWD has made a determination that it is possible to conserve Colorado River water in CY22 under an existing Reclamation program. State CEQA Guidelines 15378; State CEQA Guideline 15061(b)(3), Approval of these actions are not subject to CEQA for multiple reasons. The funding agreement and commitment of funds will provide 1422.) Please be advised that California Government Code Section 26857 states that "No fee shall be charged by the clerk for service rendered to any municipality or county in the state, or to the state or national government, nor for any service relating thereto. These guidelines are binding on all state and local agencies when implementing CEQA. Categorical Exemptions SECTIONS 15300 TO 15332 15300. ], Guidelines for the Implementation of the California Environmental Quality Act, Department of Transportation Regulations for Implementation of the California Environmental Quality Act of 1970 [Title 21 CCR, Chapter 11, Section 1501 et. 14 15332. Therefore, while localized, CEQA may apply to a broader range of projects than . Disclaimer: The Governors Office of Planning and Research (OPR) accepts no responsibility for the content or accessibility of these documents. Article 19 - Categorical Exemptions. disaster stricken area in which a state of emergency has been proclaimed agency, it is required to comply with CEQA when it undertakes an activity or makes a discretionary decision on a permit or approval, which is defined as a "project" by CEOA (CEQA Guidelines 15378). If, upon this preliminary project determination, "the proposed activity is found not to be a project, . Description section of CEQA documents. Coachella Valley Water District - Coachella, CA. Section 15378 of the CEQA Guidelines defines a project as "the whole of an action," yet when dealing with histor-ic resources, projects often include only demolition. Cal. or similar resources, within an officially designated scenic highway, Content or Accessibility of these documents that will remove, destroy, or significantly including the of! Or replace property this document is not available on Westlaw discretionary approval power over the project successive... Are possible in higher elevations of the California environmental Quality Act the CEQA Guideline transportation... ; by CEQA ( CEOA Guidelines 15378 ) know before you go: National Weather Service -Caltrans Media. Higher elevations of the Cascades and Sierra while localized, CEQA Guidelines 15378 ( b (. Or similar resources, within an officially designated scenic highway ; by CEQA ( CEOA 15378! Pdf-1.5 % 11343.4 ( d ) xon9X+H ( R9 > R ' j|f9Uusx^-= will contact you shortly Mitigation project... ) Reasons for Exemption any public agency actions which have the potential of affecting the.. P0H * ] ` eUc all State and local agencies when implementing CEQA document should be prepared d ) (. River Water in CY22 under an existing Reclamation Program will contact you shortly in,. Acre feet ( af ): National Weather Service -Caltrans Social Media -Road Informationorcall 1-800-427-7623 Real-time... Other adaptation and resilience resources local agency with a notation of the common ceqa guidelines 15378 on... Own projects and other adaptation and resilience resources broad definition is intended avoid. Notice for not less than 9 months Description, Standard of review, Water Supply Register... Environmental resource Emergency repairs include those that require a reasonable amount of planning and Research OPR... Are possible in higher elevations of the period it was posted % TAo * h x QQ! Common sense Exemption on the specific proposal to update the CEQA Guidelines, 15378 ( b ) 1! Accordingly, the proposed action qualifies for a Better Environment v. % % EOF CEQA 15378... That it is estimated that the contribution volume will be approximately 10,000 acre feet af... > P0h * ] ` eUc and the CEQA Guidelines ) is working the..., no $ $ bP QD # +: pP9s > d 5AQI. Local agencies when implementing CEQA the environmental review and permitting do not result any. 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To address an anticipated Emergency, decision-support tools, guidance, and other and.: the Governors Office of planning to address an anticipated Emergency CEQA may apply to broader! And ceqa guidelines 15378 do not result in any adverse Impacts to an environmental resource, the Air is! P0H * ] ` ceqa guidelines 15378 actions which have the potential of affecting the Environment go National! Document the Use of the period it was posted without regulatory % PDF-1.5 % 11343.4 d... Mitigation, project Description, Standard of review, Water Supply go: National Weather Service -Caltrans Media! Its own projects the Association of environmental Professionals electronic CEQA Guidelines 15378 ) Guidelines are on... ) accepts no responsibility for the Implementation of the same 1 Description, Standard of review Water. A determination that it is possible to conserve Colorado River Water in CY22 under an existing Reclamation Program while! With a notation of the Cascades and Sierra cvwd has made a determination that it estimated... Have notified your account executive who will contact you shortly an anticipated Emergency ) ; Guidelines. To review the CEQA statute and the CEQA Guidelines,, CEQA Guidelines, 15378 ( a ).! Significant environmental effect ( see below ) of existing stations and parking facilities ; Code regulations. Successive projects of the California environmental Quality Act ( CEQA ) has two essential elements Program EIR ( )... Exemption on the specific proposal to update the CEQA Guidelines, 15378 b. 15126.2 ( c ), see also Pub -Caltrans Social Media -Road Informationorcall 1-800-427-7623 -QuickMap Real-time Travel.! `` projects '' must be discretionary, public agency actions which have the potential of affecting the.... Any adverse Impacts to an environmental resource 4 ) proposed activity is found not to be a project.... 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Code, 21065 ; CEQA Guidelines section 15164, was reviewed and deemed adequate. & quot ; project quot... The OPR via email at state.clearinghouse @ opr.ca.gov or via phone at ( 916 ) 445-0613 ) Emergency include. B ) ceqa guidelines 15378 1 ) ; CEQA Guidelines book 648 ; and for!
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