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CEQA and the EIR Process


The process and rules that govern the approval of the management plan for Jackson State are extremely complex. The process is guided by the California Environmental Quality Act (CEQA), which specifies in great detail the steps that must be taken and the contents of the Environmental Impact Review (EIR).

Alternative Analysis

The EIR describes the environmental impacts of the proposed management plan and those of a number of alternative plans. The alternative plans considered are intended to cover the full range of feasible alternatives.

The potentially feasible alternatives must be discussed in "meaningful detail," and provide sufficient "information to the public to enable it to understand, evaluate, and respond" to the agency's conclusions. The discussion should "contain facts and analysis, not just the agency's bare conclusions or opinions."


When the proposed plan (the preferred alternative) has significant environmental impacts, the EIR must propose mitigations that would eliminate, minimize or repair the greater environmental impact of the preferred alternative.

In instances where mitigations are not feasible or the agency does not wish to adopt a feasible alternative that would avoid them, the EIR must describe the unavoidable environmental impacts and, in instances where it chose to accept them, the reasons why it made this choice.

CEQA Compels Description Not Choice

Note well that CEQA does not compel the agency to adopt the most environmentally desirable alternative, but only to describe feasible alternatives in meaningful detail and to adopt mitigation measures or to justify their non-adoption.

Substantive EIR Comments

To have a significant impact on the EIR process, comments must point out errors, inconsistencies, omissions of data or analyses, conclusions not based on evidence, or failures to provide discussion required by CEQA.

The agency needs to respond to respond adequately to such substantive comments prior to certification of the final EIR. Failure to do so would provide the basis for a legal challenge to a certified (approved) EIR, and if the court agreed with the challenge, the EIR would be found invalid.

Expressions of Opinion

Substantive EIR comments require careful review of the EIR and plan documents. However, expressions of personal opinion and experience are extremely valuable and important for the Jackson State EIR.  You don't need to be an expert or know the details of the management plan to make an EIR comment.

Jackson State is a state forest. This means it is owned by the people of California. Because it is a redwood forest, all people of the world have a stake in its future. CDF, the governor, and legislators all take public opinion into account.

The politicians need to know that public opinion overwhelmingly supports restoration. By sending your EIR comment in support of restoration, you create a public record of great political value. Please do your part to save your forest.

Send your EIR comment now.