Comments on the Draft EIR for Phillip Road Project (State Clearinghouse No.2025060240)

Summary: The attached document is a March 23, 2026 comment letter from the Center for Biological Diversity to the City of Roseville regarding the Draft Environmental Impact Report for the Phillip Road Project, State Clearinghouse No. 2025060240. The Center argues that the DEIR does not satisfy CEQA because it allegedly fails to adequately analyze, disclose, and mitigate several significant environmental impacts. The letter focuses heavily on the proposed project’s data center components, especially their potential impacts from diesel backup generators, large electricity demand, major water use, operational noise, greenhouse gas emissions, and effects on sensitive biological resources. Major themes include: Air quality and public health: The Center argues that the DEIR does not adequately analyze diesel backup generator emissions, especially nitrogen oxides and particulate matter, in an area already facing serious ozone and PM10 nonattainment issues. The letter emphasizes nearby sensitive receptors, including homes and schools, and recommends stronger mitigation such as zero-emission construction fleets, air monitoring near receptors, grading restrictions, and limits on diesel equipment use. Energy demand: The letter criticizes the DEIR for not sufficiently evaluating the project’s large electricity demand, especially in light of rapid data center growth, AI-related power consumption, grid stress, and cumulative demand from other regional data centers. Water demand: The Center contends that the DEIR does not adequately address the project’s projected water use, including the estimated water demand for data center cooling. It argues that reliance on recycled water should be made a mandatory, enforceable mitigation measure and recommends closed-loop or zero-water-evaporation cooling systems. Noise impacts: The letter states that the DEIR acknowledges significant noise from construction, HVAC systems, and diesel generators, but does not adequately analyze health impacts on residents or impacts to wildlife. It recommends additional acoustic design review, rooftop screening, noise walls, acoustic wraps, and other sound attenuation measures. Greenhouse gas emissions: The Center argues that the DEIR does not require all feasible GHG mitigation. It objects to permissive language such as “may utilize” solar photovoltaic systems and urges stronger requirements, including 100% rooftop solar and parking-lot canopy solar for data centers, LEED or comparable standards, energy-efficient design, water reuse, and low-carbon construction practices. Biological resources: A substantial portion of the letter argues that the DEIR inadequately analyzes and mitigates impacts to special-status species and habitats, including burrowing owl, Swainson’s hawk, Crotch’s bumble bee, western spadefoot, northwestern pond turtle, vernal pool branchiopods, wetlands, and riparian habitat. The Center repeatedly criticizes proposed mitigation as vague, deferred, unenforceable, or insufficient, and calls for stronger surveys, larger buffers, compensatory habitat mitigation, long-term monitoring, and permanent habitat protection. Conclusion and legal posture: The Center urges the City to correct the alleged deficiencies and prepare an EIR that complies with CEQA. It also reminds the City to preserve the full administrative record in anticipation of potential legal remedies.