combined into one document (since the EIS and EIR have the same elements for the most part). Said document, however, must be processed through both the CEQA and NEPA approval steps. Laws in other states As of 2005, fourteen states as well as the District of Columbia have CEQA-style laws requiring impacts be reported for projects. CEQA influenced many of these laws, and New York state's law used CEQA as a foundation. Connecticut's Environmental Policy Act (CEPA) is modeled on CEQA and requires lead agencies to prepare an Environmental Impact Evaluation (EIE) that is very similar in nature to California's EIR. The various state laws are not entirely similar to CEQA, as most only apply to public projects (rather than all public actions, like CEQA) and few have as rigorous review standards. Litigation CEQA's broad scope and lack of clear thresholds often lead to litigation, both by groups that support development, and individuals and agencies opposing such development. CEQA plaintiffs such as community and environmental groups often challenge projects with negative declarations, on the grounds that EIRs should have been carried out. Litigation also occurs on the grounds that EIRs are too brief or overlooked possible impacts, as there are no guidelines for the length or content of the EIRs. Plaintiffs also sometimes accuse developers of a practice called piece-mealing, by which projects are analyzed incrementally by parts to make the environmental impacts appear smaller to the overseeing agency. CEQA plaintiffs succeeded on one such claim in June 2009, concerning an expansion of the Chevron Richmond Refinery, the largest employer in Richmond, California. The judge ruled that Chevron erred by defining the project inconsistently, and the city of Richmond erred in allowing Chevron to piece-meal its project, and in allowing Chevron to develop a mitigation plan after the project begins. The judge consequently ruled the EIR to be insufficient to meet CEQA's requirements, ordering the preparation of a new EIR covering the whole, accurately defined project before the refinery's expansion could proceed. Settlements Plaintiffs in CEQA lawsuits seek various forms of redress, such as amending the EIR, preparing a new EIR, agreeing to mitigation measures, or paying money to local agencies to offset environmental impacts. Criticisms CEQA lawsuits (and threats of CEQA lawsuits) are frequently used by groups that want to block a proposed project for reasons than its environmental impacts. Carol Galante, a professor of Affordable Housing and Urban