This article claimed that the Sierra Club "sent in 1,100 separate comments on the DEIR and other comments on the General Plan alternatives, compared to 303 other comment letters coming in for both documents." These figures were attributed to Heidi Tschudin, manager of the General Plan project. Further, allegedly quoting her, she said "the club submitted a document around 900 to 1,000 pages, some are attachments, some not."

In the article, comments made by Conservation Chair Alice Howard to the reporter were badly scrambled, misparaphrased, and in part fabricated. The same may have happened to Ms. Tschudin. Of course, the Sierra Club is now being blamed for delaying adoption of a new General Plan. Apparently, it matters not whether the DEIR was or wasn't well done.

FACTS

How many pages were in the three volumes of the DEIR?		about 2060
How many pages of comments did the Maidu Group submit?		115
How many pages total?		about 615

Supporting documents thus made up over 80% of the total number of pages.

What of the charge of 1,100 "separate comments"? Response to this is harder. What is a "separate comment"? In the news article, our "separate comments" were compared with the total number of letters submitted by others, an apples-and-oranges comparison.

We "bulleted" comments needing a response to highlight them in other text. (No, the 115 pages were not a long list of "faults" or points to be answered.) Some of these "bullets" were followed by one sentence; some were several sentences, to clarify the question. Counting these, we got 349 bullets, not 1,100. Compare with about 2400 points responded to by the County in the DEIR on the 1996 general plan.

Not all bulleted sentences need much response. Some merely pointed out apparent typos that made a table difficult to understand, corrected misstatements of fact, or called attention to things that might have been overlooked. Most comment letters don't try to be comprehensive, but, rather, focus on selected topics. We tried to be comprehensive, thus taking more pages.

How many pages were in the three volumes of the draft General Plans?	about 1036
How many pages were in our comments on these volumes?	25

Unlike the DEIR comments, comments on the draft plans don't have to be responded to by the County.

COST

The article reports that the County has spent more than $2.4 million on the General Plan since Spring 2002. It should be remembered that that sum has been spent to remedy the problem the County alone caused by failing to comply with law in adopting the 1996 General Plan, which was then set aside by the California Superior Court.

Public comments are designed to raise issues and problems in DEIRs and draft general plans in time for them to be addressed and corrected before final approval. The County should welcome extensive comments as a way to improve the prospect of legal compliance this time around.

Whatever the cost of responding to public comments, it is sure to be minor compared with funds already spent and the consequences of another failure.