by eight residents of a neighboring city, challenging the validity of the developer's EIR. The developer had originally prepared an EIR for a commercial development on the site, then prepared a supplemental EIR to include a proposed 75,000 seat stadium situated within 3,000 feet of homes in that neighboring city; the plaintiffs argued that a single new EIR studying the entire project was required. State officials said the abrogation ended an abuse of CEQA by individuals seeking to obstruct the project; at the signing ceremony, Governor Arnold Schwarzenegger said he would "terminate the frivolous lawsuit." A plaintiff in the lawsuit said the abrogation "opens up the door for other developers... to hire lobbyists... and get exemptions from the environmental laws." An environmental lawyer said that the slow economy would probably encourage developers to seek more abrogations, as legislators become more eager to stimulate job growth. Categorical exemptions Several categorical exemptions for projects are listed under Title 14 of the California Code of Regulations, Chapter 3, Article 19. These exemptions cover projects that do pose a significant impact to the environment and fit within the description of the several categories listed under Article 19. A common categorical exemption used by agencies is 15301 for maintenance of existing facilities. Since the project is already built, the project often has no significant new impacts. Agencies do not have to file any CEQA findings for categorically exempt projects. They can be legally challenged by the public on whether the project must undergo CEQA. The lead agency can file a Notice of Exemption (NOE) to trigger a 35-day statute of limitations period for legal challenge or, if no NOE is filed, a 180-day statute of limitations applies. Negative Declaration (ND) / Mitigated Negative Declaration (MND) After the initial study is completed, the lead agency can then determine if the project could have a significant impact on the environment. The lead agency must propose mitigation measures to reduce any impacts to less than significant "to the maximum extent feasible." The lead agency then prepares a draft Negative Declaration (ND) or Mitigated Negative Declaration (MND) and publishes the document for public review for at least 21 days. After comments are considered, the lead agency can either recirculate the ND/MND if public comments required the project scope to substantially change, or the lead agency can adopt the document. The Lead agency must file a Notice of Determination (NOD)