[BrianSac]

Seems like nobody wants to talk about CEQA.

I should do some more research on this law, but figured I would start here as I respect your opinions. I suspect a great amount of you are urban planners, developers, nimbys, construction workers, politicians, preservationists, conservationists, and activists.

Is CEQA untouceable, amendable, taboo?

Is it abused?

Is CEQA unconstitutional, are parts of it unconstitutional?

Have studies been conducted showing the merits or de-merits of the law?

How much more do projects cost because of CEQA?

What is the connection between CEQA and Environmental Impact Reports?

Any horrors stories regarding CEQA?

Any succeses because of CEQA?

[SacRising]

Below is the text from AB 1387 from Sacramento Assemblyman Dave Jones. I don't have an answer to most of your questions, but this bill seems to be aimed at providing a small incentive to certain, very specific types of urban development. AB 1387 is now signed into law, and hopefully will succeed in encouraging more infill, smart growth, TOD (pick a buzzword).


FACT SHEET

Assembly Bill 1387 (Jones)




Summary

AB 1387 helps combat sprawl by encouraging the development of housing close to transit and close to where people work and shop. AB 1387 gives local governments more discretion to weigh the benefits of infill residential development and decreased sprawl versus traffic impacts for small infill housing developments near transit.


Background

California suffers from sprawl. Over the past decade, tens of thousands of new, low density, single family subdivisions have sprawled over what were formerly open space, farmland, and important natural habitat. Sprawl also results in people living further from where they work, increasing commutes, traffic congestion and air pollution.


At the same time, there are thousands of acres of vacant or underutilized infill parcels in urbanized areas suitable for infill residential development or mixed use residential developments which remain blighted and vacant because of costs associated with infill development versus the lower costs associated with sprawling “greenfield” development.


Development of infill housing in urbanized areas where people work and shop and near transit also reduces vehicular miles traveled, traffic congestion and air pollution.

Local governments are in the best position to weigh the relative benefits and costs of encouraging more infill residential development near transit, with attendant decreases in sprawl, traffic congestion, and air pollution, versus the increase in local traffic impacts of an infill residential project. Under CEQA, however, local government’s ability to decide how best to balance these competing considerations is constrained by a mandate to mitigate all traffic impacts association with the project. The costs of these mitigations are then passed on to the developer, who, given the choice between lower cost sprawling greenfield development versus higher cost infill development, opts for sprawl.

The goal of this bill is to allow local government to better balance the benefits of infill versus the traffic impacts of new infill housing. The bill does not eliminate the requirement to do an EIR and study the traffic impacts. It does not eliminate a local government’s authority to impose traffic mitigation if the local government wants mitigation. It simply eliminates the requirement in state law that traffic mitigation must be carried out on these infill projects.





This Bill

AB 1387 provides that a local government is required to analyze, but is not required to mitigate, the traffic impacts of small infill residential developments near transit in communities with over 100,000 in population. AB 1387 also expressly provides that local governments retain the discretion to require traffic mitigation. The bill is limited to the following types of projects:
· The project must be on an “infill site” in an “urbanized area” as already defined in the CEQA statute;
· The project cannot exceed 100 units;
· The project must be no more than four acres;
· The project must have a minimum density of 20 units per acre;
· The project must be within one-half mile of a transit stop;
· The EIR must be no more than 5 years old, and no major changes can have occurred in the project area after the EIR;
· The EIR was not certified with over-riding considerations with respect to the traffic, circulation, and transportation policy of the general plan or local ordinances;
· The project must be in compliance with the traffic, circulation, and transportation policies of the general plan and applicable ordinances of the local government;
· The local government with jurisdiction over the area where the project is located must require that the mitigation measures approved in a previously certified environmental impact report applicable to the project be incorporated into the projectNothing in the bill restricts the authority of a local government to adopt feasible mitigation measures if the local government elects to do so, especially with respect to pedestrian and bicycle safety.

[plinko]

Seems like nobody wants to talk about CEQA.

How's that exactly?

I should do some more research on this law, but figured I would start here as I respect your opinions. I suspect a great amount of you are urban planners, developers, nimbys, construction workers, politicians, preservationists, conservationists, and activists.

Is CEQA untouceable, amendable, taboo?

No, I believe that it has been legislatively amended before. Taboo?

Is it abused?

Yes.

Is CEQA unconstitutional, are parts of it unconstitutional?

All a matter of legal opinion and the basic beliefs of 'the good of many' vs. 'the good of a few'.

Have studies been conducted showing the merits or de-merits of the law?

Yes.

How much more do projects cost because of CEQA?

Varies greatly. ALL projects are subject to CEQA review, but not ALL projects have environmental impacts that require mitigation. A full EIR on any project is at least an 18 month process and can cost upwards of $50-$100K...or even more...

What is the connection between CEQA and Environmental Impact Reports?

An EIR is the most costly form of review. It establishes that A: there are environmental impacts and B: the mitigation measures required go beyond the scope of recommendations that can be made by the local Building and or Planning Department.

Any horrors stories regarding CEQA?

There are many.

Any succeses because of CEQA?

There are equally as many.

-----------------------------------------------

I'm curious what your interest is in CEQA? Is it because you are wondering why projects in your city have to have EIRs?

BTW, the bill shown in SacRising's post is a step in the right direction, however it only relates to traffic. Projects must still go through the process of being reviewed for other potential environmental impacts (go to http://www.ceres.ca.gov/ceqa/ for a full listing of what those might be).

[BrianSac]

I'm curious what your interest is in CEQA? Is it because you are wondering why projects in your city have to have EIRs?


Well, its seems as if Sacramento was prime for so much "quality" development beginning say around 1995, and so many projects both in the denser areas and suburbs were stopped by the very threat of a costly EIR or the threat of being sued based on CEQA, or mitigated to death by CEQA.

Quality projects: Private and public colleges. Hospitals, arenas and stadiums, housing, TOD's, high-density development. Expansion of our airport.

What got built instead: huge suburban homes in the suburbs and rural areas. Big box retail. The very things CEQA should mitigate for.

Private donation money to get projects started is wasted on EIR's, CEQA, and more importantly the results of mitigation.

Opposition to any project is greatly empowered by CEQA. Nimbys and anti-growth advocates have an unfair advantage based on CEQA.

Projects that did make it through this firewall, took 4 times as long.

The Sacramento that could have been by now was stopped based on our EIR's and CEQA.

What really bothers me is this will continue. Case in point: Caltrans threat to sue one of the most high quality, high-density land saving projects in the urban core; based on CEQA. (500 Capitol Mall, building) This is insanity, imo.

Is Sacramento better off because of EIR's and CEQA? Doesnt seem like it, we have endless urban sprawl, but very little TOD's, nor no new grand cultural amenties: zoo, museum, arena, etc. No new private college.

[BrianSac]

Plinko,
Thank you for responding and answering those questions. :banana:

[BrianSac]

SacRising,
You too, Thanks, kudos, for that research.:banana:

[bmfarley]

Well, its seems as if Sacramento was prime for so much "quality" development beginning say around 1995, and so many projects both in the denser areas and suburbs were stopped by the very threat of a costly EIR or the threat of being sued based on CEQA, or mitigated to death by CEQA.

Quality projects: Private and public colleges. Hospitals, arenas and stadiums, housing, TOD's, high-density development. Expansion of our airport.

What got built instead: huge suburban homes in the suburbs and rural areas. Big box retail. The very things CEQA should mitigate for.

Private donation money to get projects started is wasted on EIR's, CEQA, and more importantly the results of mitigation.

Opposition to any project is greatly empowered by CEQA. Nimbys and anti-growth advocates have an unfair advantage based on CEQA.

Projects that did make it through this firewall, took 4 times as long.

The Sacramento that could have been by now was stopped based on our EIR's and CEQA.

What really bothers me is this will continue. Case in point: Caltrans threat to sue one of the most high quality, high-density land saving projects in the urban core; based on CEQA. (500 Capitol Mall, building) This is insanity, imo.

Is Sacramento better off because of EIR's and CEQA? Doesnt seem like it, we have endless urban sprawl, but very little TOD's, nor no new grand cultural amenties: zoo, museum, arena, etc. No new private college.
I wouldn't call myself a tree hugger but I am familiar with California Environmental Quality Act. The National Environmental Policy Act too.

In it's most basic form, CEQA defines a procedure to identify what and how to review a project for environmental impacts. And, how, if at all, to mitigate impacts. But, the final product of the CEQA process is not the end all for a project. The report generated is used by the planning agency to form its recommendation going before a coucil or board of supervisors. It's not a pass/fail product.

If developers are afraid of CEQA and doing EIR's... then they are either cheap, ignorant, or just not serious. Some EIRs do cost a lot of money to do. Sometimes over $1million for large complicated projects.

I believe the media is to blame for much of the fear. They often cite findings of an EIR as critical or major milestones, and/or the public review of them. Other milesstones of greater weight do not get as much attention... so the public is left only with a weighty impression of the EIR.

Concerning Caltrans suing a developer or somebody because of CEQA... I bet it's more about findings daylighted in the EIR and specific impacts to roadways Caltrans is responsible for. The developer should be responsible for mitigating their impacts. The only reason Catrans would sue would be if some entity is saying they are not going to do what the EIR says they should??? That is my guess.

I bet it's like if your neighbor somehow built a well or spring on their property and it ended up having excess water flowing out of it and onto/across your property and damaging your lawn... shouldn't your neighbor be responsible for fixing what they did?

About Sacramento.... I don't think CEQA can be blamed for the urban sprawl you're referring to. Perhaps it stopped some of it. But, it certainly improved what could have been. At the end of the day it's the elected officials that are to blame.... for approving general plans and zoning ordinances allowing sprawl to occur. An ignorant population and nimby's are also to blame for opposing dense developments. Today we're learning density is good. Compact development reduces the need to use auto's and/or the distances we need to drive. Less dense development actually creates more traffic! But, despite that, some people just don't care. They want their house on a cul de sac and the supposed safety and quality of life that isolation provides them.

[BrianSac]

If developers are afraid of CEQA and doing EIR's... then they are either cheap, ignorant, or just not serious. Some EIRs do cost a lot of money to do. Sometimes over $1million for large complicated projects.

bmfarly, thanks for your input.

The very process of EIR's and CEQA can be daunting and unfair. Sort of like when your apply for a building permit for a new and/or existing home; and find out your city has changed so many rules & codes, some of the new code changes are down right ridiculous and frivoluous, others makes sense. There needs to be a balance.

If an EIR costs $1million, what was gained for that $1million? We know that the cost will be passed down to the buyers of the development. What did the buyers gain? What did the community or environment gain?

believe the media is to blame for much of the fear. They often cite findings of an EIR as critical or major milestones, and/or the public review of them. Other milesstones of greater weight do not get as much attention... so the public is left only with a weighty impression of the EIR.

Your above comment sounds like lawyer talk or it came from a politician.

I think most California's have little fear of EIR's or even know of CEQA, and if they do know about CEQA; it is overwhelmingly supported. Nine times out of 10; the media sensationalizes an EIR story in favor of "tree huggers".

Concerning Caltrans suing a developer or somebody because of CEQA... I bet it's more about findings daylighted in the EIR and specific impacts to roadways Caltrans is responsible for. The developer should be responsible for mitigating their impacts. The only reason Catrans would sue would be if some entity is saying they are not going to do what the EIR says they should??? That is my guess.

The City of Sacramento and the developer are trying to do the right thing by building a high-density project in the heart of the urban core (Capitol Mall). The EIR probably does daylight the impacts to these nearby roadways. Who writes the EIR? Are those "impacts" factual? What % of EIR writers are "tree huggers", hmm?

Depending on how the EIR is written, the door is now open-wide for future lawsuits. How much of the cost of mitigations should the developer be responsible? Seems rather unfair to me that the developer should bear the full cost; when the developer is actually improving the environment in some cases.

In the Caltrans case; its a matter of who is actually responsible for the impacts to the nearby roadways. Maybe those impacts are distorted or not factual. What Caltrans was suggesting was unfair. If Caltrans sues (they temporaily dropped the threat) the suit could be based on a distorted EIR.

The worse part is the time it takes to sort this all out in court. The courts may side with the developer and/or the City of Sac, but by the time it is settled; the developers cost to complete the project now costs twice as much. This is the "tree huggers" trump card; and something needs to be done about that.


The developer should be given CREDIT for the benefits the project will provide to the the community and economy; AND, its benefits to the environment by building TOD's, placing their project near existing public transit, and building in existing urban centers.

About Sacramento.... I don't think CEQA can be blamed for the urban sprawl you're referring to. Perhaps it stopped some of it. But, it certainly improved what could have been. At the end of the day it's the elected officials that are to blame.... for approving general plans and zoning ordinances allowing sprawl to occur. An ignorant population and nimby's are also to blame for opposing dense developments. Today we're learning density is good. Compact development reduces the need to use auto's and/or the distances we need to drive. Less dense development actually creates more traffic! But, despite that, some people just don't care. They want their house on a cul de sac and the supposed safety and quality of life that isolation provides them.

I agree. Most of what you say is true. But, did CEQA really "improve what could have been" and what was the cost both in time and money to the developer, consumer, and the community. These "improvements" as well as the costs need to be documented.

[BrianSac]

Anyone have CEQA (EIR) horror stories to tell?

I want to here of those horror stories, document them, and get a good Sac Bee writer to write about them (Blair, do you want to write this story?)
The LA Times should do an expose on these stories, as well.

Sactown Magazine: Would a story like this have a place in your magazine?

[BrianSac]

Does Anyone have a CEQA (EIR) horror story to tell?

I want to here of those horror stories, document them, and get a good Sac Bee writer to write about them (Blair, do you want to write this story?)

The LA Times should do an expose on these stories, as well.

Sactown Magazine: Would a story like this have a place in your magazine?

:banana:

[bmfarley]

Anyone have CEQA (EIR) horror stories to tell?

I want to here of those horror stories, document them, and get a good Sac Bee writer to write about them (Blair, do you want to write this story?)
The LA Times should do an expose on these stories, as well.

Sactown Magazine: Would a story like this have a place in your magazine?
Brain,
CEQA is not going to go away. And, I doubt very much it will change substantially in the future. I also doubt very much any amount of discussion here is going to daylight anything of much significance for anyones benefit.

If you're really interested in learning more I am sure there is a CEQA blog around somewhere.

Be cognizant that environmental review is not a cottage industry. There are many many highly qualified people working directly on environmental studies... or reviewing them for adequacy from a third party perspective. That, and that the professions involved have ethics standards provide me enough confidence that the material in an EIR is legitimate and information is adequate for elected officials to act upon when considering a project.

If interested I'd also suggest searching and reviewing the CEQA Initial Study list. Ask yourself in an uncritical perspective why the specifc subject is being considered and why it's important to protect. Be cognizant that that list was developed and refined over the years after thousands of people and elected officials have weighed in at various times. I am sure the courts have too.

[BrianSac]

bmfarley,
I find any suggestion for quelling any discussion on any topic to be most alarming. This is an open forum for free discussion, and I thank you for expressing your opinions and providing the information that you provided.

Why not expose these CEQA horror stories. If anything, it will keep the topic alive. CEQA does need to be reformed. And I really wish any lawyer would be willing tackle it on its Constitutionality.

Which politician is willing to take this on, would have to be very brave.

I still do not know who actually writes EIR's. Are the authors of EIRs biased in their opinions, afterall, isn't most of what is in an EIR, simply opinion.

I suspect, CEQA, was writted, in part, as a money-making tool for lawyers.
Environmental law is quite lucrative.

[mthd]

I still do not know who actually writes EIR's. Are the authors of EIRs biased in their opinions, afterall, isn't most of what is in an EIR, simply opinion.

in most jurisdictions the studies in an EIR are written by separate private consultants. whether they are contracted to the city or the project sponsor or a primary environmental consultant varies by local government rules, but they are always responsible directly to the city or county, since it is the responsibility of local government to certify the EIR.

as an example, in most of northern california the data from the wind section comes from the uc davis wind tunnel and a small group of researchers there who perform pedestrian comfort evaluations. the requirements of the evaluation are based on city criteria - how many points are studied, what determines a significant negative impact, etc.

the infamous traffic sections are usually written by traffic consulting firms, e.g. the CHS Consulting Group.

there is usually a lead environmental consultant who coordinates all the subconsultants, requests and gathers the information from the architect, writes the project description and other filler language. many firms undertake this work, from major engineering outfits like URS to smaller local firms like turnstone consulting and specialist environmental consultants like EIP or ESA in the middle.

having been involved in lots of EIRs in northern california, i would characterize it as a frustratingly slow process which has the best of intentions. the intentions of CEQA are good. the complexity of the process and the degree to which it is beholden to city governments of varying quality and attorneys of varying integrity - not so good.

[Alta California]

Good questions Briansac

Is CEQA untouceable, amendable, taboo?


Not yet the third-rail of California politics like Proposition 13 since the Governor and some Democrats in the legislature want to loosen up the law to allow more housing units to be constructed. The details will be controversial of course. But exempting urban infill projects and affordable housing are already part of CEQA guidelines.

Is it abused?

It depends on who you are asking. "Abuse" IMO would be using CEQA to prevent a project because of socio-economic impact which CEQA explicitly says can not be used as a reason to stop a project. A recent court decision, nevertheless, has started to chip away that protection.

How much more do projects cost because of CEQA?

There are added application fees for developers whose projects are not CEQA exempt. It depends on the city or county where the application will be processed. These are not too much as it ranges between $5,000-10,000. Other added CEQA costs are the consultant fees developers charge to come up with the multitude of studies that would be required in order to see whether a full-blown EIR would be needed. It sounds like a drop in the bucket, but non-exempt CEQA projects can be as small as an 11,000 sq. ft. building on a vacant lot.

The REAL costs is in the length of time it takes to process CEQA projects. Though the horrible stories of CEQA review taking decades to complete is an extreme outlier (its usually done within one year depending on the project), any time not spent on building is money wasted. Many builders are dependent on loans and sometimes they underestimate the length of the CEQA review costing them thousands a day in interest.

What is the connection between CEQA and Environmental Impact Reports?


EIR is part of the CEQA review process. The short of it is like this:
1. initial study to determine impact.
2. whether the impact can be mitigated, or not significant. If none of the above, see #3.
3. EIR

[Alta California]

^^^I'm answering this as city planner and just starting to get familiar with CEQA. Of the dozens of large projects we processed, I can count on one hand in the past three years that has been blocked by some drummed-up litigation involving CEQA. Half of those projects, IMO, deserved it. We are a city in an environmentally-sensitive region. There are projects being planned left-and-right on top of earthquake faults, flood plains, steep mountain cliffs, Indian burial grounds, and endangered species habitat.

[BrianSac]

mthd and Alta California,

Thank you for all this information. This is exactly what this forum is intended to do. This is exactly the kind of information the masses need to see. It was most enlightening. :banana: :awesome:

California Citizens,
I would love to hear more! :banana:

[mthd]

... But exempting urban infill projects and affordable housing are already part of CEQA guidelines.

...

There are added application fees for developers whose projects are not CEQA exempt. It depends on the city or county where the application will be processed. These are not too much as it ranges between $5,000-10,000. Other added CEQA costs are the consultant fees developers charge to come up with the multitude of studies that would be required in order to see whether a full-blown EIR would be needed. It sounds like a drop in the bucket, but non-exempt CEQA projects can be as small as an 11,000 sq. ft. building on a vacant lot.


the exemptions for 'urban infill' projects are often not used, in my experience. at least in the bay area, everyone knows that if you don't do a full or partial EIR you will get sued by sue hestor or someone like her.

as for the cost, i would estimate that on a large scale urban project of the type that are discussed here, the total cost is in the $500,000 to $1,000,000 range.

[Alta California]

the exemptions for 'urban infill' projects are often not used, in my experience. at least in the bay area, everyone knows that if you don't do a full or partial EIR you will get sued by sue hestor or someone like her.


Which is something that is probably not an abuse of CEQA per se, but the fault of the judges such nonsense from moving through the judicial process. On the other hand, CEQA guidelines are just that, guidelines. There are many other legal reasonings that one can use that trumps the guidelines. "Fair argument" is one that's been used before according to an article I found through Google (that research save me thousands in Lexis-Nexis fees! ).

I'm still on the fence on whether CEQA goes "too far." Successfuly CEQA challenges seem to be almost always the projects that do have significant environmental impact like the Ahmanson Ranch in LA/Ventura county which would affect endangered species, rare habitats, traffic, and once you get Indian heritage in the mix.... Many of these "outrageous" lawsuits have more merit than people give them credit for.

But the cost of the delays, as I've wrote before, is enough to drive builders in either stopping a project or be hesitant in starting up one. NIMBYs know this.

Yet, even with CEQA, I'm surprised that the state built more than 200,000 units in 2005.

Housing production has not kept pace with the State’s housing needs, particularly in the coastal metropolitan areas and housing need has worsened, especially for renter households and low-income owner households throughout the State. During the 1980s, 2.1 million units were built whereas the 1990s saw only 1.1 million units built. While the average annual need is projected at approximately 220,000 housing units, construction has lagged substantively below the need. Since 1999, less than 170,000 residential new construction permits have been issued each year. During 2006, 163,449 new homes and apartments were built, a reduction of 45,972 units compared to the 208,972 in 2005 which represented the highest production since 1989.
http://www.hcd.ca.gov/hpd/hc030507.pdf

[bmfarley]

bmfarley,
I find any suggestion for quelling any discussion on any topic to be most alarming. This is an open forum for free discussion, and I thank you for expressing your opinions and providing the information that you provided.
Don't be alarmed. Why would I want to quell something here? CEQA is not threatened. I am just trying to help you learn about something that you expressed interest in and do not think you'll find what you're looking for here. Although I applaud those above that have responded. It's consistent with what I am familiar with and has also reminded me of some stuff.

[BrianSac]

Don't be alarmed. Why would I want to quell something here? CEQA is not threatened. I am just trying to help you learn about something that you expressed interest in and do not think you'll find what you're looking for here. Although I applaud those above that have responded. It's consistent with what I am familiar with and has also reminded me of some stuff.

Ya, changing CEQA is a longshot. But I think it needs some reform. Its clearly abused; and I think the masses dont know that.

What are you reminded of?

I viewed your high-speed train blog. I'm really excited about this. It would be interesting to see those EIR's. Why is Sac in the 2nd phase?

[BrianSac]

[QUOTE=travis bickle;2986498]Well, I wasn't going to chime in here because I've said so much of this before. but as someone who has guided many projects from land aq. to bond exoneration, I can say that the CEQA process is excruciating and often amounts to legal extortion with what most would consider, at best, mixed results.



This is 100% true. Every city in California is subject to CEQA and I have had it add over a year to a project. For the 4-S Ranch master project near San Diego, the CEQA process took nearly five years. Then each individual project was required to file individual EIRs. This added up to an additional year. This doesn't include the time it takes to get to Tentative Map and then Final Map which can easily be 18 months. If your project has a HOA: then add another 18 months to develop your CCRs, articles of incorporation and budget. These are not all on a linear time line and much can be done concurrently, but on a straight-forward, relatively non-controversial project, I'll usually schedule 18-30 months from concept to Final Map.

As has been repeatedly mentioned here by many, opposition groups know that they can greatly delay this process relatively inexpensively by repeatedly asking for changes or new studies and by appealing any arbitrary decision. In San Diego, there is a two week to one-month period during which a "final" decision can be appealed by any group or individual. The fee to appeal is all of $100. Most large projects in SD go through a four phase process (staff, neighborhood, planning commission, council). Each of their decisions is subject to appeal. Opposition always waits until the last minute to file in order to maximize delay (remember, 30 days already), and, given the typical staff time needed for response, can easily mean adding two months to the process. Right there, you've added eight months to your project and it cost your opponents all of $400.

Now you've been paying all of your consultants this entire time, plus you have some kind of carrying costs on the land. This delay has now cost you $500,000 and often much, much more. It's cost your opponents $400.

All projects have a finite window of opportunity for success and often that window is less than the CEQA process affords. Your opponents know this and are well aware that delaying a project often equals killing a project.

Not every place has a "CEQA" or equivalent (Texas and the Phoenix areas to name two), but obviously every place in California does. Although I strongly believe in some kind of revue process that encourages local participation and contribution, in my view CEQA has been perverted into a mechanism for slow, but expensively sure project death.

CEQA costs communities millions of dollars every year and yet we still have choking traffic and unencumbered sprawl.

Would anyone call that a success?

Care of travis bickle :previous:

[BrianSac]

However it was intended, I know how it is being used. CEQA requires public agencies to review the environmental impacts of proposed projects, to prepare and review environmental impact reports (EIRs), negative declarations, mitigated negative declarations and to consider feasible alternatives and mitigation measures that would substantially reduce significant adverse environmental effects. It was amended again I think just this month so you can count on additional delays as each jurisdiction interprets these changes in their own way on their own schedule (it's not uncommon for a project to come to a screeching halt while the local discretionary body decides how they way to interpret and enforce a particular code/law).

Claiming that because all projects don't require an EIR is a straw man argument because every project goes through some kind of review that is lengthy and costly.

The result is killed projects and an artificially low housing supply.

Usually the people who squeal loudest for affordable housing are the same people who keep supply low (through the review process) and thus keep prices high. Not just through killing projects, but by adding so much to cost which then have to be passed on to the consumer (remember, you're competing for investment dollars).

We're describing a process that costs millions and produces results with which few are pleased.

Perhaps it's time for a better solution.

Care of travis bickle :previous: