(3) The EIR Properly Analyzed Growth Inducing Effects

CBD asserts that the EIR did not "consider the growth-inducing impacts of the EITP." The quoted statement consists of CBD's entire argument on this point. The EIR considered growth inducing effects in Section 6.3, following the requirements of Guidelines section 15126.2, subdivision (d). That Guideline requires an EIR to describe the potential for economic or population growth, or the construction of additional housing. If a project would remove an obstacle to growth or, conversely, overburden existing facilities to the point that they would need to be improved, such a result must also be discussed. Finally, an EIR should discuss "the characteristic of some projects which may encourage or facilitate other activities that could significantly affect the environment[.]"

Section 6.3 covers all these points. At page 6-9, the EIR discusses population and housing. Next, at page 6-10, the EIR discusses the potential for the EITP to remove obstacles to growth or increase demands on public facilities and services. The EIR then considers whether the EITP will "encourage or facilitate other activities" describes factors, such as federal law and policy, that support the development of renewable power in the Ivanpah Dry Lake Area independent of the EITP.

Because CBD's allegation is so vague, it is difficult to determine why CBD believes the growth-inducing impacts analysis to be invalid. That analysis is derived from the review that was performed in order to prepare the EIR, and CBD's summary claim does not address the material the EIR relies upon or refer to other material that might suggest a different approach was warranted.⁵¹ Because CBD's allegation only states a conclusion-the growth inducing effects analysis is invalid-without setting forth "specifically the ground or grounds on which the applicant considers" the EIR to be unlawful, it does not demonstrate error.

⁵¹ Neither CBD nor WWP appear to have addressed the question of growth inducing impacts in their comments on the draft EIR.