Sculpture of Buddha in Japan

On August 31, the First Appellate District issued its decision in Coastal Hills Rural Preservation v. County of Sonoma, which centered on the applicable standards and appropriateness of proceeding on a subsequent mitigated negative declaration (SMND), rather than an environmental impact report (EIR) under CEQA, where changes had been incorporated in a religious facility use permit that was originally reviewed under a mitigated negative declaration (MND). The appeals court affirmed the trial court judgment for the lead agency, Sonoma County, ruling that use of the SMND was appropriate and that the revised permit was not inconsistent with the County’s “Resources and Rural Development” general plan designation.