Related articles:
An annotated Table of Contents for the Draft Environmental Impact Report
The Documents of the General Plan Draft Environmental Impact Report
The Gish Gallop — and Brandolini’s Law
The Draft Environmental Impact Report (EIR) for Arcata’s General Plan and Gateway Area Plan is here. It weighs in at 1,990 pages, and is, in my view, almost unreadable.
The draft EIR (known as the DEIR) became available to the public on Monday, January 29, 2024. The public comment period on this draft document runs from January 31 until March 18, 2024, 5 p.m.
As stated in the official “Notice of Availability” (highlighting added):
The purpose of public review of the DEIR includes: sharing expertise, disclosing agency analysis, checking for accuracy, detecting omissions, discovering public concerns, and soliciting counter proposals (CEQA Guidelines Sec 15200).
Comments received on the draft EIR will be addressed in the Final EIR. Further official information can be found on the City of Arcata’s Environmental Impact Report website page.
It is 1,990 pages long
This draft EIR document is 1,990 pages long. Or is it?
Of the 1,990 heft of pages in this draft EIR, only about 30 to 50 pages contain material that is significant enough to actually read. Parts of that 1,990 pages are required by California Environmental Quality Act (CEQA) guidelines. But a great part of this document consists of copy-and-paste duplication of material. So it’s not really 1,990 pages of useful information — not at all.
The main portion of the draft EIR is 581 pages. One of the appendixes, Appendix E, the Environmental Database Review data, is largely composed of long lists of the data. It’s 1,173 pages. Of that, there are two pages that are high significant, buried there within those 1,173 pages. (In the PDF file, they are pages 910 and 911 — maps of the locations of the environmental records sites of the Gateway area.)
Because the size and complexity of this draft EIR are so vast — and the need for corrections and omissions so great — there will be a series of articles here on Arcata1.com to present both the actual draft document and commentary on it.
The Gish Gallop: Extraneous information masks the omission of necessary information
Readers of Arcata1.com will be reminded of the article “The Gish Gallop — and Brandolini’s Law” which dates from June 2022 — over 1-1/2 years ago, from the earlier days of the General Plan update and Gateway Area Plan discussion. From the opening text of that article:
Impediments to creating a good Gateway Plan for Arcata
When necessary information is not presented; when important considerations are ignored; when statistical input is manipulated; when “facts” are made up; when personal bias prevails over reality; when bluffing and a distortion of knowledge appears with regularity; and when impossible-to-comprehend statements are promoted as truth — all of which we have regularly seen over this past year and a half — then the results are an impediment to the creation of a plan that is good for Arcata.
The first “Notice of Availability” contained a typographical error on the date when this EIR was expected to be adopted.
The PDF for the first “Notice of Availability” document has a document date of 1/19/24, 11:22:04 AM. It states: “The Arcata General Plan 2045 is anticipated to be adopted in late 2022.
Six days later, in a document dated 1/25/24, 9:17:22 AM, the “revised” version emerged, with the corrected information:
The Arcata General Plan 2045 is anticipated to be adopted in late 2022 early 2024.
The error in itself is small. But it unfortunately is a further example of the general sloppiness we’ve seen in important figures over these past two years.