Adequacy and Certification of the FEIR

The FEIR must be certified by the lead agency under CEQA before a project may be approved. Certification consists of two steps. First, the agency must conclude that the document has been completed in compliance with CEQA, and second, the agency must have reviewed and considered the FEIR prior to approving the project. Additionally, the lead agency must find that the FEIR reflects its independent judgment (Pub. Res. Code § 21082.1(c)(3).)

The FEIR must contain specific information according to the CEQA Guidelines, Sections 15120 through 15132 (CEQA Guidelines).4 The various elements of the FEIR satisfy these CEQA requirements. The FEIR consists of the DEIR, with revisions in response to comments and other information received. Appendix 2 of the FEIR contains the comments received on the DEIR; individual responses to these comments appear in Section H of the FEIR.5

The Commission must conclude that the FEIR is in compliance with CEQA before finally approving PG&E's request for a certificate of public convenience and necessity. The basic purpose is to insure that the environmental document is a comprehensive, accurate, and unbiased tool to be used by the lead agency and other decisionmakers in addressing the merits of the project. The document should embody "an interdisciplinary approach that will ensure the integrated use of the natural and social sciences and the consideration of qualitative as well as quantitative factors."6 It must be prepared in a clear format and in plain language.7 It must be analytical rather than encyclopedic, and emphasize alternatives over unnecessary description of the project.8 Most importantly, it must be "organized and written on such a manner that [it] will be meaningful and useful to decisionmakers and the public."9

We believe that the FEIR meets these tests. It is a comprehensive, detailed, and complete document that clearly discusses the advantages and disadvantages of the environmentally superior routes, PG&E's proposed route, and various alternatives. We find that the FEIR is the competent and comprehensive informational tool that CEQA requires it to be. The quality of the information therein is such that we are confident of its accuracy.

The Commission should certify the FEIR.

4 Cal. Admin. Code §§ 15122-131. 5 CEQA Guidelines, § 15132. 6 Id., § 15142 7 Id., §§ 15006 (q) and (r), 15120, 15140. 8 Id., §§ 15006, 15141; Pub. Res. Code § 21003(c). 9 Pub. Res. Code § 21003(b).

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