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California Land Use & Development Law Report

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California Land Use & Development Law Report

California Land Use & Development Law Report offers insights into legal issues relating to development and use of land and federal, state and local permitting and approval processes.

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September 13, 2013

Senate Bill 743: Legislature Sends CEQA Amendments to Governor

Following a week of intense negotiations, the Legislature has sent Governor Brown a set of  CEQA amendments.  Senate Bill 743 replaces – at least for now -- Senate Bill 731, which had become an unwieldy mass of 15 separate CEQA revisions.  (See our April 26 post

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September 5, 2013

All About Drakes Bay and Oysters, Little Oysters.

In a case the court described as pitting "an oyster farm, oyster lovers and well-known 'foodies' against environmentalists," the Ninth Circuit has upheld denial of a preliminary injunction against the Interior Secretary's decision not to extend a permit for commercial oyster farming at Point Reyes National Seashore.  View blog post
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August 28, 2013

County Can Establish Winery Uses By Right Despite Environmental Impacts

San Diego County's decision to permit visitor-serving wineries by right has survived CEQA and general plan challenges.  San Diego Citizenry Group v. County of San Diego, 219 Cal. App. View blog post
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August 20, 2013

Faulty Greenhouse Gas Analysis Sinks EIR

An environmental impact report must not only identify a proper significance threshold for a project's greenhouse gas (GHG) emissions; it must then correctly apply that threshold.  The EIR for a Wal-Mart Supercenter failed this test in Friends of Orov

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August 13, 2013

No CEQA Review Required For Adoption of CEQA Thresholds of Significance

A court of appeal today rejected a CEQA challenge to an air pollution control district's published thresholds of significance for air pollution impacts.  California Building Industry Association v Bay Area Air Quality Management District, No. 135335 (First District, July 13, 2013).  

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August 6, 2013

Use Of Future Baseline In CEQA Analysis Approved By California Supreme Court

The California Supreme Court has both resolved a split in the appellate courts and forged new law on the baselines agencies may use to assess projects' environmental effects under CEQA.  Neighbors for Smart Rail v. Exposition Metro Line Construction Authority, Case No. S202828 (Cal.

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August 5, 2013

City Council's Interpretation of General Plan Prevails Despite Conflict With Plan's Land Use Map

A city council has sweeping authority to interpret the city's general plan.  That authority trumped a successful referendum campaign designed to block a residential development project, according to the court's decision  in Orange Citizens for Parks and Recreation v.

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August 2, 2013

Offsite Conservation Easements Are Feasible Mitigation For Loss Of Agricultural Resources According to Appellate Court

The First District Court of Appeal has ruled an EIR inadequate for failure to explore fully the use of conservation easements to mitigate impacts to agricultural resources. Masonite Corporation v. County of Mendocino, No. View blog post
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July 31, 2013

Specific Limitations Period In Government Code Prevails Over Statute of Limitations In CEQA

A 30-day limitations period for a challenge to a project that is exempted from CEQA by Government Code section 65457 applies rather than the 35-day limitations period that ordinarily applies after a notice of exemption is filed, according to the court in View blog post
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July 28, 2013

Under the Public Records Act, agencies must allow access to land use databases.

The California Supreme Court has unanimously held that a public agency must allow access to a database of information on land use parcels, rejecting the claim that such information is subject to the "computer software" exemption under the Public Records Act. 

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July 25, 2013

Pre-Approval Disclosures Between Agency and Applicant Waive Privileges In CEQA Cases.

The Fifth Appellate District has issued another in a series of decisions regarding administrative records in CEQA cases.  The court held that the "common interest doctrine" does not protect otherwise privileged communications shared by a developer and an agency prior to approval of a project because the two cannot be considered to be advancing any shared interest at the preapproval stage.&

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July 22, 2013

County Can’t Use Growth Control Initiative to Bar Previously-Approved Project

It takes an unusual set of circumstances for a California appellate court to find a regulatory taking based on denial of a discretionary land use entitlement.  But those circumstances existed in a recent case in which the court not only found a taking, but upheld an award of attorney's fees to the developer for both the inverse condemnation and related civil rights claims.  View blog post
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July 19, 2013

Coastal Commission May Not Review City Nuisance Abatement Ordinance Passed In Good Faith

The California Coastal Commission lacks jurisdiction to review a city's adoption of a nuisance ordinance because a municipality's enactment of an ordinance is not an appealable action.  However, the city must demonstrate that it exercised its nuisance abatement power, pursuant to Coastal Act section 30005(b), in good faith, and not as a pretext for avoiding its obligations under the Coas View blog post
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July 19, 2013

Ninth Circuit Clarifies ESA’s “Cumulative Effects” Requirement

The Ninth Circuit Court of Appeals has confirmed two important points under the federal Endangered Species Act: 
  • A "cumulative effect" under the ESA is different from a "cumulative impact" under NEPA
  • No "cumulative effects" analysis is required in informal ESA section 7 consultations.
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July 14, 2013

County Could Not Make Density Bonus Conditional Upon Compliance With Local Affordable Housing Requirements

A local agency may not condition the availability of a density bonus upon provision of more affordable housing than the minimum required under the State Density Bonus Law.  Latinos Unidos Del Valle De Napa Y Solano v.

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