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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.

Real Estate and Housing Construction
January 28, 2024 CEQA

The First Project Approval Establishes the Appropriate Statute Of Limitations for CEQA Challenges, Even When the CEQA Document Is Later Re-Adopted

A court of appeal held a CEQA challenge time-barred because it was not commenced within 30 days after a Notice of Determination (NOD) was filed for approval of a subdivision map based upon a Mitigated Negative Declaration (MND). View blog post
Gavel banging
November 28, 2023 Housing

Court Invalidates Ordinance Reducing Floor Area Ratio on Residential Lots

The Housing Crisis Act of 2019, which enacted Government Code section 66300, generally precludes a city from reducing the intensity of land use on a parcel where housing is allowed below what was allowed on January 1, 2018. View blog post
Housing Real Estate
November 28, 2023 Housing

Housing Accountability Act Provision That Prohibits an Agency From Requiring a Rezoning When Zoning Is Inconsistent with the General Plan Inapplicable Where City Found Zoning Consistent

A court rejected a developer's attempt to take advantage of provisions in the Housing Accountability Act that prohibit a City from requiring a rezoning when zoning is inconsistent with the General Plan.  View blog post
image of the road cutting through the forest
November 14, 2023 CEQA

Class 7 CEQA Exemption Requires Only a Showing of Protection of a Natural Resource, Not the Entire Environment, and a Potential For Environmental Impacts Does Not Prevent Use of a CEQA Exemption

A court upheld an ordinance that restricted development standards in designated overlay zones to protect wildlife corridors, finding that it did not establish a "use" that would be subject to certain requirements of the Surface Mining and Reclamation Act (SMARA).  View blog post
Housing Buildings
October 20, 2023 CEQA

Court Upholds EIR for UCSF Parnassus Expansion Against Wide-Ranging CEQA Claims

The First District Court of Appeal has approved an EIR analyzing a proposed fifty percent increase in density at the Parnassus campus of the University of California, San Francisco. View blog post
Water Coastal
October 9, 2023 CEQA

Fair Argument Standard Did Not Apply to Claim Regarding Exception to CEQA's Historical Resources Categorical Exemption

This case addressed both application of CEQA's categorical exemption for renovation of historical resources and application of an exception to the exemption that turned on the question whether the project complied with Secretary of Interior standards regarding renovation of historic structures. View blog post
Water Hydro Power
September 22, 2023 CEQA

Monterey Water Saga Continues: County’s Approval of Desalination Plant Upheld Against CEQA Challenges

A court of appeal has upheld Monterey County's approvals for a desalination plant, rejecting challengers' claims that uncertainty regarding the availability of source water for the plant necessitated additional CEQA review. View blog post
Real Estate Sector image, view of commercial area with new construction
September 8, 2023 CEQA

Court Approves EIR’s Climate Change Analysis for Community Master Plan

The Third District Court of Appeal has held that Sacramento County's environmental impact report for a master planned community complied with CEQA's requirements for analysis of greenhouse gas emissions. View blog post
Gavel with scale
August 10, 2023 CEQA

Trial Court Cannot Retain Jurisdiction if Terms of Peremptory Writ of Mandate are Fully Satisfied

The trial court improperly retained jurisdiction of a CEQA challenge after the City of San Diego filed a return to the peremptory writ of mandate confirming that it had rescinded the project approvals and thereby satisfied the terms of the writ. View blog post
Education
August 7, 2023 CEQA

School Districts’ Challenge to EIR Based on Inadequate School-Facilities Funding was Speculative

The Court of Appeal rejected a challenge by two school districts to a specific plan EIR, finding the districts' claim that the EIR should have analyzed off-site impacts resulting from inadequate school facilities to be speculative. View blog post
coastal highway on sunny day
August 2, 2023 California Coastal Act

Coastal Commission Has De Novo Authority Over Issuance of Coastal Development Permits

The court upheld the authority of the California Coastal Commission to decide appeals of coastal development permits under a de novo standard of review. View blog post
Housing Real Estate
July 20, 2023 CEQA

County’s Claimed Failure to Comply with CEQA Was Not a Defense to Enforcement of Encroachment Laws

Property owners who acted illegally by blocking parking on a public street fronting their houses were not entitled to use the County's alleged noncompliance with CEQA as a defense to actions enforcing encroachment laws.  Anderson v. County of Santa Barbara, 94 Cal.App.5th 554 (2023).

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Water Hydro Power
July 16, 2023 CEQA

EIR for Relicensing of Oroville Dam Adequately Evaluated Environmental Impacts

An environmental impact report need not discuss impacts that are too speculative in nature for proper evaluation or assess economic costs not linked to a physical change in the environment. County of Butte v. Dept. of Water Resources, 90 Cal.App.5th 147 (2023).

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Modern Building
July 7, 2023 CEQA

Compensatory Mitigation Infeasible for Loss of Historic Building

The Court of Appeal upheld the City's determination that compensatory mitigation for the loss of a historic building in the form of funding of other historic preservation was not feasible because there were no other buildings in the downtown areas with the same architectural style, period of significance, and purpose. Preservation Action Council of San Jose v.

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Two Buildings
July 7, 2023 Land Use Subdivision Map Act

Lot Created on 1869 Map and Conveyed With Fewer Than Four Other Lots Was Lawfully Subdivided

The First District Court of Appeal held that a single deed conveying four or fewer contiguous lots can qualify for a presumption of legality under section 66412.6(a) of the Subdivision Map Act so long as the lots are separately described (including by reference to an antiquated subdivision map) and all other requirements of section 66412.6(a) are satisfied.

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