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On January 4, 2016, the Third Appellate District published its opinion in North Coast Rivers Alliance v. Kawamura, 2015 Cal. App. LEXIS 1178. In the opinion, the court found a programmatic EIR for a program to deal with the invasive light brown apple moth to be inadequate.  Because of the EIR’s “artificially narrow” project objective to eradicate the pest, its alternatives analysis did not consider a control program and focused solely on eradication methods. For more information on this case, our previous blog post is available at:

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