Critical Coastal Area 29
Wednesday, March 24 , 2010
David Bomberger, Chair
County of San Mateo
455 County Center, 2nd Floor
Redwood City, CA 94063
Re: Big Wave Project Environmental Impact Report
Dear Mr. Bomberger,
For many years it has been the practice of the San Mateo County Planning Department to have both the DEIR and Response to Comments (FEIR) prepared by an outside consultant, without the applicant or his consultants interfering or influencing the process. This best practice ensures that the EIR is reasonably independent of influence from the applicant.
The Big Wave Project Facilities Plan was written by the applicant as an advocacy document. Some information from the Facilities Plan was used by the EIR consultants in the DEIR, so already there have been questions as to the independence of the DEIR.
CEQA reports must be unbiased which is not possible when the applicant writes the report. It is not appropriate to allow a proponent of a project to prepare any of the legally required environmental documents.
The proposal to delegate preparation of documents to Scott Holmes, Big Wave Project Director is improper because he is a strong proponent of the project and he is concerned about the future of his developmentally challenged child.
The Big Wave Project Environmental Impact Report should be independently prepared.AREA29