2. Overarching Principles and Issues

Parties raised a number of overarching issues that impact the outcome of phase 1 of this proceeding. Rather than addressing the merits of these arguments separately, we address these arguments, with one exception, in the following discussions on specific proposals. The one issue we address now is whether the adopted rule revisions or ordering paragraphs implicate the California Environmental Quality Act (CEQA). This matter is addressed here because the issue is not raised in the context of any rule proposal but instead only appears in broader discussions. We find that CEQA does not apply to the measures adopted today. The measures do not require any activity that would be considered a project under CEQA.