Comments on Council Policy G-3 and the 1992 CEQA Guidelines
June 17, 2026
Re: Council Policy G-3 and CEQA Guidelines Dear Chair Ramirez and Members of the Council Policy and Procedures Committee: Mountain View YIMBY would like the Committee to include the 1992 CEQA Guidelines (referenced in Council Policy G-3) as part of the FY 2025-2027 City Council Work Plan item on updating council policies. The 1992 CEQA Guidelines dictate how the city follows CEQA, and they were converted from Policy to Guidelines in 1992 due to concern about how out of date the policy was. However, the Guidelines have likewise been left untouched for decades, even as CEQA and the city have changed considerably.
Re: Council Policy G-3 and CEQA Guidelines
Dear Chair Ramirez and Members of the Council Policy and Procedures Committee:
Mountain View YIMBY would like the Committee to include the 1992 CEQA Guidelines (referenced in Council Policy G-3) as part of the FY 2025-2027 City Council Work Plan item on updating council policies.
The 1992 CEQA Guidelines dictate how the city follows CEQA, and they were converted from Policy to Guidelines in 1992 due to concern about how out of date the policy was. However, the Guidelines have likewise been left untouched for decades, even as CEQA and the city have changed considerably.
In particular, there is tension on choosing the preferred project to analyze under CEQA, especially when there is a significant delay between preferred project selection and final project approval. The process of choosing a preferred project takes time and blocks CEQA work, as was the case for choosing R3’s selective upzoning. And the choice of preferred project effectively caps the scope of any eventually approved project, since any choice for a larger project afterwards (no matter how much larger) necessitates a Supplemental EIR or Addendum, which would add more delay. Staff currently chooses not to analyze broader-scope scenarios as alternatives, as seen with the responses to our comments regarding the R3 Zoning Draft EIR. As such, we ask CPPC to consider modifying the way the city addresses CEQA by always analyzing the maximum reasonable scenario as an alternative, in order to give the Council the greatest envelope for flexibility and to ensure CEQA work starts quickly.
Thank you for your consideration.
David Watson, on behalf of Mountain View YIMBY
