Open Letter to Calera Parkway Project Manager Mohammad Suleiman of Caltrans:
After a brief flip through the Final Environmental Impact Report (FEIR), it is clear to me that the choice to combine a California Environmental Quality Act (CEQA) document with a National Environmental Policy Act (NEPA) document is confusing to Caltrans. While you reassure the reader that doing a combined EIR/EA is standard practice at Caltrans, there are a few things to remember. Please let me explain:
It appears routinely throughout the FEIR that when faced with an insurmountable CEQA issue that can't be mitigated under the CEQA guidelines, the FEIR says that you have relied on the less restrictive NEPA standards to mitigate one of dozens of environmental impacts that would literally end the project's progression, if you had done a mere CEQA document.
Stating over and over again that you are Caltrans and this is how you do it may pass muster at the water cooler, but not out in the real world where people live and roam about freely.
I'd like to give you one little tip about doing a combined CEQA/NEPA document: You still have all the insurmountable CEQA issues whether or not you hide behind NEPA. This project is in California, not Texas or Florida (although I must admit I would love to read a Carl Hiaasen column in the Miami Herald, or better yet one of his funny novels on this entire subject; I know Carl and his city desk editor-in-chief). In the end, this project must conform to California state law, not Caltrans' "bubble boy" law.
I look forward to seeing further hijinks by Caltrans environmental staff and the Calera Parkway Project Development Team. Your EIR/EA plus the backroom politicking (see PDT minutes 1 through 30) have provided hours of fun.