Environmental Impact Report
On February 3, 2010, Sufism Reoriented’s attorney, Marie Cooper, submitted a letter (see below for the full text) to the Department of Development and Conservation requesting that the County prepare an Environmental Impact Report on our proposed Sanctuary instead of the more limited study then underway. Two weeks later the County approved our request.
We made this request even though the professional environmental consultants we have engaged concluded that any impacts from our project will be relatively light.
An applicant would not normally request an EIR if it were unlikely to be required. But we have concluded that it is in our best interest for the County to proceed with an EIR at this time, rather than the smaller environmental study typically deemed sufficient for a project like ours.
- A small cost now, against a potentially large cost later. Even when a project has little environmental impact, the standards are not very high for a member of the public or the County to require an EIR at any point in the process. If an EIR were required after the public hearings, the effect would be very costly to us, both in time and money. In essence, requesting an EIR now is like buying insurance. We pay a premium against an unlikely event so that in case that event occurs, we are not devastated. Since there is relatively little added cost in time and expense of doing an EIR at this stage, we believe it is cost-effective and timely to do an EIR now.
- Reassurance of our neighbors. An EIR will help reassure our neighbors that any potential environmental impacts of our new sanctuary will be fully addressed and meet CEQA standards.
- Increased flexibility for the County. An EIR will give County decision-makers more flexibility to weigh and balance factual evidence to arrive at the best possible decision regarding our Land Use Permit Application.
Therefore, we decided to request the County to proceed with an Environmental Impact Report to achieve these objectives.
Next Steps
Additional studies will now be conducted. During this time we will continue to meet with neighbors as we have been doing for the past two-and-a-half years, to answer questions about our faith, our congregation, and our sanctuary.
Full Text of Letter Requesting an EIR
February 3, 2010
Lashun Cross
Senior Planner
Contra Costa County
Dept. of Conservation and Development
651 Pine Street, 3rd Floor, North Wing
Martinez, CA 94553-0095
Re: Sufism Reoriented - Request That County Prepare EIR
Dear Ms. Cross:
I am writing on behalf of Sufism Reoriented, the applicant for the new sanctuary project. We request that the County prepare an EIR for the project even if staff would otherwise prepare a proposed Mitigated Negative Declaration for the Planning Commission’s consideration.
As you know, an EIR must be prepared only when the record contains evidence that there may be unavoidable significant impacts. A Mitigated Negative Declaration is permitted when there is no such evidence. The studies conducted by our consultants have not revealed any unavoidable significant impacts. Experience at the existing sanctuary establishes that the new sanctuary will generate few vehicle trips. Also, the new sanctuary project proposes redevelopment of a developed site in a developed neighborhood. All these factors indicate that a Mitigated Negative Declaration would most likely be appropriate for the project.
However, the new sanctuary has generated controversy among a significant minority of our neighbors, and we want to make sure that all the issues they raise are fully vetted. An EIR would also give the County decision makers more flexibility to weigh and balance evidence and arguments, allowing them to arrive more easily at the best possible decision in this matter.
We understand that preparation of an EIR would involve more time and effort than would preparation of a Mitigated Negative Declaration, and Sufism Reoriented confirms its commitment to pay all reasonable processing costs, including those associated with an EIR. We also understand that the decision regarding what document to prepare lies solely in the County’s hands. We make this request to alert the County to our position, confirm our agreement to pay costs, and explain why an EIR would be appropriate
Thank you for your consideration of this matter.
Sincerely yours,
Marie A. Cooper Bingham McCutchen LLP