2. Residual CEQA Claims

CBD and WWP both close their rehearing applications by claiming, in summary language, that our environmental review was inadequate. (CBD Rehrg. App., pp. 5-6; WWP Rehrg. App., p. 5.) The majority of these parties' claims simply list broad sections of the EIR (e.g., project description or alternatives analysis) that they allege are in error. CBD makes only one elaboration on its summary claims. It states that "the `project as a whole' include[es] connected actions represented by PPAs and projects in the CAISO queue that are relied on in the Decision regarding need[.]" (CBD Rehrg. App. p. 6.) WWP makes some specific claims, alleging, for example, that a distributed PV alternative should have been considered, and that the EIR's discussion of the dangers of an infectious disease affecting the desert tortoise should also have addressed whether or not construction dust was a factor related to the disease. The rehearing applications further refer to the other documents filed by these parties in the underlying proceeding and as part of the CEQA process.

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