6. Environmental Review

Applicants state the transactions that are the subject of this application do not constitute a "project" under the California Environmental Quality Act (CEQA) since Applicants are not requesting authorization related to facilities construction or other activity that would constitute a direct or indirect physical change in the environment.

We do not need to address Applicants' position on whether the transfer of control constitutes a project under CEQA because we are denying the application for other reasons.