The Register articles have consistently failed to accurately report the causes for opposition to the Syar project ("Napa County a victim of CEQA abuse," Oct. 19). The primary problem is the flawed, inadequate EIR (environmental impact report) -- which is based on incomplete or faulty analysis.

It is not just that the opponents want less or no expansion -- what citizens want, and what has yet to happen, in all the years this project has been in the works -- is a comprehensive, accurate and unbiased evaluation of its environmental impact. Such an EIR -- which would truly give citizens and planners a sound basis on which to make decisions affecting Napa for the 35 years of the permit and beyond -- is not the document we have.

The EIR as it stands does not allow a full evaluation of the risks and benefits of the project. Folks who have a lot of experience with these things say it is the worst EIR they have ever seen. Major flaws exist in the areas of traffic, air quality, water, noise and health risk assessment. Opponents have not just "done their own research" as the Register article claims. They have hired experts in these fields and submitted extensive reports that detail the flaws -- undercounting truck trips, misclassifying vehicle trips, missing primary noise reports, impermissible deferment of GHG reduction plans, reducing traffic and air quality impacts by claiming without documentation that 100,000 tons of aggregate are shipped by rail per year within a 14-mile distance.

The list goes on. That citizens have done this on their own dime is an unacknowledged benefit to the county.

Last week, for the first time, county said that the EIR does not have to prove the need for the expansion, flippantly comparing it to requiring a winery having to demonstrate the need to produce more wine. It is difficult to see why the county would make such a statement since Syar has argued from the beginning that its primary objective is to ensure a reliable local source of aggregate. The county echoes these comments, using language in reports and recommendations about meeting the project's objectives of meeting local need. Napa citizens and taxpayers are getting GHG impacts from the project’s impacts on groundwater, air quality, traffic, noise, loss of ag land, loss of a nonrenewable resource in the aggregate.

Responsible analysis requires the production of data on the assertions of local need and analysis of remaining reserves of the existing quarry. Syar could, but will not, provide the weigh tag data to support its arguments.

During the period of the EIR, according to traffic reports, the majority of the aggregate went out of county. Now, Syar states the opposite. Public Records Act requests to the county for weigh tags from the baseline study period 2004-2008 to corroborate this have only yielded incomplete, heavily redacted records for one year - 2014. Syar refuses to release this information now contending it is proprietary -- not open to public inspection. There is no way to independently confirm what Syar claims. Supporters of the quarry expansion who are concerned about length of the CEQA review process should really be asking why this essential information has been withheld.

Opponents of the quarry expansion are accused of being NIMBYs. This is not “my” backyard, this is not “your” backyard. This is OUR backyard, this is our air, our water, our open space, our watersheds.

As with the other issues currently being debated countywide -- where developments threaten community character, drain resources and affect the environment -- the problem here is that the Valley’s finite resources are not being managed wisely. To do so will take a change in the business-as-usual culture of approval by the county.

NVR version: On Syar expansion: Facts matter.