CEQA Requires Separate Evaluation Of Mitigation Measures And Alternatives Even Where Mitigation Measures Are Incorporated Into Project Design

In Trisha Lee Lotus et al. v Department of Transportation et al. (1^st Dist., Div. 4, 1/30/14 A137315) ___ Cal.App.___ ____, 2014, the court of appeal upheld a claim by the appellants that Caltrans failed to comply with CEQA because its EIR did not consider potential mitigation measures aimed at lessening the impact of the underlying highway construction project on old growth redwoods.  The court held that failing to separately identify and analyze the significance of impacts to root zones of old growth redwood trees before proposing mitigation measures for such impacts subverted the purpose of CEQA by omitting material necessary to informed decision-making and public participation.