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General Request for EIR Insufficient to Exhaust Administrative Remedies When Challenging Reliance on Categorical Exemption

Plaintiff did not exhaust administrative remedies when challenging the City’s approval of a homeowner’s development project on the ground that a Class 1 categorical exemption was inapplicable. Arcadians for Environmental...more

Project with Potentially Significant Greenhouse Gas Emissions Improperly Approved Based on an EIR Addendum

The City of Irvine violated CEQA by approving a development project based on an addendum to a program EIR containing insufficient information regarding the project’s greenhouse gas emissions and by relying on CEQA’s Class 32...more

CEQA Categorical Exemption Must Be Agendized under Brown Act

The City of Thousand Oaks violated the Ralph M. Brown Act by adopting a CEQA exemption without having listed the exemption as an item on its agenda for at least 72 hours before the meeting. G.I. Industries v. City of Thousand...more

Dam Operations Authorized Under 1954 Statute Potentially Included Protection of Endangered Species.

The Ninth Circuit held that statutory language defining the scope of operations of Twitchell Dam was sufficiently broad to potentially include releases of water to facilitate migration of Southern California Steelhead to the...more

CEQA Review Not Required for Water Allocations That Were Part of Earlier Project

A CEQA challenge to water allocations by the City of Los Angeles and its Department of Water and Power were barred by the statute of limitations because the allocations were under leases approved years earlier. County of Mono...more

Agencies Must Preserve Emails For CEQA Record of Proceedings

An agency’s duty to preserve documents for inclusion in the record of proceedings under CEQA prevails over a local agency’s document retention and destruction policies. Golden Door Properties v. Superior Court (County of San...more

Judicial Council Shortens Tolling Period for Statutes of Limitations

As we previously reported, on April 6, 2020, the California Judicial Council adopted an emergency rule suspending (or “tolling”) the running of statutes of limitations on civil claims during the state of emergency declared by...more

Fees Under Private Attorney General Doctrine Denied Where CEQA Lawsuit Neither Enforced Important Rights Nor Conferred Significant...

The court of appeal held that attorney’s fees under the private attorney general doctrine could not be recovered in a CEQA action in which plaintiff obtained a preliminary stay of the project but the project proponent...more

EIR’s Project Description May Present Alternative Development Options and the Agency May Approve A Variant of an Analyzed...

An EIR’s project description may identify alternative development schemes proposed for a single project, and the agency may approve a modified version of the project that incorporates elements of one of the alternatives...more

City Approval of Agreement for Tree Removal Triggered 90-Day Statute of Limitations Under Planning and Zoning Law

Broadly construing Government Code § 65009, which establishes a 90-day limitations period for claims under the Planning and Zoning Law, an appellate court held that approval of an agreement allowing removal of trees...more

CEQA Year In Review 2015

In 2015 the California appellate courts continued to chart new ground as they grappled with some of CEQA’s most difficult and controversial questions. The Supreme Court of California led the way, issuing four opinions on...more

California Supreme Court Sets Oral Argument in Key CEQA Case

The California Supreme Court has announced that the oral argument in California Building Industry Association v. Bay Area Air Quality Management District will take place on October 7, 2015, in San Francisco. The CBIA case...more

A State Agency’s Duty To Mitigate Significant Environmental Impacts Does Not Depend On A Legislative Appropriation Of Funds For...

The California State University system may not condition its funding of mitigation for off-site impacts of a campus expansion project on receipt of a legislative appropriation earmarked for that purpose, according to a...more

California Supreme Court Upholds Most Commonly Used CEQA Categorical Exemptions

The California Supreme Court has issued its long-awaited decision in Berkeley Hillside Preservation v. City of Berkeley, No. S201116 (March 2, 2015). The Court’s decision clears up some of the ambiguity that surrounded the...more

California Supreme Court Poised To Decide Key CEQA Questions: The Court’s Lineup For 2015

The California Supreme Court’s involvement in CEQA cases has been relatively limited since he statute’s enactment in 1970, with the court taking  review of at most one or two appellate court decisions a year.  The last two...more

CEQA Year In Review 2012

In This Issue: - Project Approvals Triggering CEQA ..Chung v City of Monterey Park (2012) 210 CA4th 394 ..Tuolumne Jobs and Small Business Alliance v Superior Court) 210 CA4th 1006 (petition for review pending,...more

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