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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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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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July 12, 2013

Tentative Map Life Extended Again for Two Years

Governor Jerry Brown has signed into law AB 116, which again extends the life of tentative maps by two years.  The move recognizes that, despite the rebounding housing market in many cities, many approved maps in California that are set to expire still cannot be processed because of persistent adverse economic conditions.  Unlike the three other statutory extensions enacted since 2008, View blog post
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July 8, 2013

Large Solar Energy Project Survives Williamson Act And CEQA Challenge

The Sixth District Court of Appeal has given a boost to utility-scale solar projects by rejecting the types of Williamson Act and CEQA challenges that are often brought against those projects.  Save Panoche Valley v.

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July 2, 2013

Judicial Review of Environmental Impact Reports: Is There Really A Need for CEQA Reform?

Every few years, with El Nino-like regularity, a wave of interest in CEQA reform sweeps through the business community, accompanied by pleas to the legislature to overhaul the statute.  In the end, few substantive changes are made.  This year is no exception. (See June 14th post).

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June 26, 2013

U.S. Supreme Court Holds That Monetary Exactions are Subject to Nexus and Rough Proportionality Requirements

In a 5-4 decision, the United States Supreme Court expanded the reach of the requirement that there be a "nexus" and "rough proportionality" between the impacts of a proposed development and governmental conditions imposed on the development.  Koontz v. St. View blog post
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June 14, 2013

CEQA and Land Use Bills -- An Update

SB 731 (Steinberg)  CEQA Modernization Act of 2013.  (Last amended May 24, 2013.  Passed to Assembly May 30, 2013
  • Aesthetic Impacts in Transit Priority Areas Not Significant.
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