In an opinion published on August 17, 2020, the Third Appellate District in Martis Camp Community Association v. County of Placer ruled that Placer County had violated CEQA by adopting an addendum to support abandonment of a roadway. Despite the statutory presumption against subsequent review under CEQA, the Third District determined that the County had … Continue Reading
On October 24, 2018, the Fourth Appellate District upheld the trial court’s decision in Save Our Heritage Organization v. City of San Diego (D073064), finding that the use of an addendum as outlined in section 15164 of the California Environmental Quality Act (“CEQA”) Guideline for approval of project modifications is valid under CEQA and does … Continue Reading
In Citizens Coalition Los Angeles v. City of Los Angeles, (2018) 26 Cal. App. 5th 561, the Second District Court of Appeal held that the City of Los Angeles’s (City) reliance on an addendum to a prior project-level EIR prepared for a Target store was legally sufficient environmental review for the approval of a later … Continue Reading
In 2014, the appellate decision in California Clean Energy Committee v. City of Woodland (“CCEC”) caught many lead agencies and CEQA consultants off-guard, by holding that the type of energy impacts analysis conducted in many EIRs actually fails to comply with CEQA. EIRs prepared post-CCEC have generally included a much more in-depth analysis of energy … Continue Reading