updated: I have been asked if my comment letter is "all inclusive" of the issues present in the DEIR. In short, not by a long shot. I had benefit of seeing some VERY STRONG comment letters wherein various issues were already identified. I saw no reason to duplicate as there are only so many hours in a day....and finding flaws with this document was like shooting fish in a barrel.....
Following is my comment letter on the Second + PCH Draft EIR. Enjoy (or not)!
Second + PCH Comment Letter Draft EIR