i'm susan brant holy, i'm an attorney who has practice on ceqa and i'm representing apellants.oing to jump into talking about the categorical exemption process. it's been confused in this situation. categorical exemptions basically are the legislators' attempt to avoid unnecessary environmental review. it's been allowed to create categories of projects that normally don't have environmental impacts. so they don't warrant the time and expense of ceqa review which we all know takes time and costs money. but basically categorical exemptions are we but thal projections. -- categorical projections. there's lots and lots of categories. but there are exceptions. and their argument standard think a explained in my letter to you and your staff agrees, the fair argument standards applies to whether there are any exceptions to the exemption claimed in this case. there's a class three exemption that's been claimed and there's dispute about whether it applies or not and we believe it doesn't apply but i think we should just jump right over that for purposes of discussion today to get to the