EDMUND G. BROWN JR.
State of California
DEPARTMENT OF JUSTICE
1515 CLAY STREET, 20th FLOOR
P.O. BOX 70550
OAKLAND, CA 94612-0550
Telephone: (510) 622-2145
August 8, 2008
By Telecopy and Email
Michael W. Wright
Director of Community Reuse Planning
1950 Parkside Drive, MS/56
Concord, CA 94519
Concord Community Reuse Plan Draft Environmental Impact Report - SCH #2007052094
Dear Mr. Wright:
Thank you for the opportunity to comment on the Draft Environmental Impact Report
(“DEIR”) for the Concord Community Reuse Plan (“Project” or “Reuse Plan”).1 It is very rare
that a large area like the former Concord Naval Weapons Station becomes available for
development in the Bay Area. We encourage the City of Concord (“the City”) to embrace this
unique opportunity to create a new mixed used, compact, transit-oriented community that will be
consistent with the State’s greenhouse gas (“GHG”) reduction goals and contribute to a lower-
carbon, sustainable future.
The goals and guiding principles that the City has adopted for the Reuse Plan -- including
to “emphasize quality development and avoid sprawl,” “address long-term impacts including
traffic and air quality,” and achieve “environmentally sustainable development” -- show the
City’s recognition of these issues and demonstrate true leadership on the part of the City.
However, as discussed below, there are some issues that should be further addressed in the EIR to
ensure compliance with the California Environmental Quality Act (“CEQA”).
First, the climate change section of the DEIR should be revised to adequately address all
sources of GHG emissions resulting from the Project, including the construction phases. Second,
the DEIR’s analysis of the significance of the Project’s GHG emissions should be clarified or
revised. Third, the DEIR should apply the appropriate time frame in assessing cumulative
impacts. Fourth, to const