At a recent CAP stakeholders meeting, Sac County staff advised us they propose to submit the CAP for adoption as an “EIR-Addendum,” meaning the CAP would circumvent normal CEQA review for technical and legal adequacy. EIR addenda are used for minor changes to projects which were previously analyzed under CEQA, when the changes don’t affect the project’s environmental impacts and environmental conditions have not changed. In this case the prior environmental analysis was for the County’s 2011 general plan amendment, ten years ago. We believe use of an EIR Addendum for the CAP is clearly unjustified. Our response, also mentioning several other concerns for the record, is attached here.