Apartment Ass'n of Greater Los Angeles v. City of Los Angeles

109 Cal. Rptr. 2d 504, 90 Cal. App. 4th 1162
CourtCalifornia Court of Appeal
DecidedAugust 8, 2001
DocketB144335
StatusPublished
Cited by18 cases

This text of 109 Cal. Rptr. 2d 504 (Apartment Ass'n of Greater Los Angeles v. City of Los Angeles) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Apartment Ass'n of Greater Los Angeles v. City of Los Angeles, 109 Cal. Rptr. 2d 504, 90 Cal. App. 4th 1162 (Cal. Ct. App. 2001).

Opinion

Opinion

JOHNSON, J.

Petitioners, the Apartment Association of Greater Los Angeles (AAGLA) and Golden Bull, Inc., appeal from the denial of their petition for a writ of mandate halting a housing code enforcement program adopted by respondent city without an environmental impact report under the California Environmental Quality Act (CEQA). 1 We affirm.

Facts and Proceedings Below

Petitioners are a nonprofit association representing residential landlords throughout the city of Los Angeles and a landlord which owns and operates residential properties in the city.

The dispute in this case concerns the city’s adoption of a systematic code enforcement program 2 which requires inspection of approximately 750,000. residential rental units at least once every three years and repair of any units found to be in violation of the city’s building, safety, fire or health regulations. This program replaced an interim code enforcement program the city adopted the previous year. 3 Prior to the enactment of these “proactive” code enforcement programs, rental property was inspected only when the city received a complaint. (Under the permanent code enforcement program, the city will still respond to complaints.)

Petitioners appeared before the city council in opposition to the permanent code enforcement program. They took issue with the city’s position the permanent program would not have a significant impact on the environment *1166 and, therefore, an environmental impact report (EIR) was not required prior to adoption of the program. In support of their argument the program could have a significant effect on the environment, petitioners submitted declarations from two urban planners, Sims and Silvern, who had not testified concerning the interim code enforcement program. Petitioners’ experts explained why, in their view, the code enforcement program was likely to “create significant environmental impacts within the meaning of [CEQA] by adversely affecting the city’s affordable rental housing stock and ultimately the environmental setting of the city’s neighborhoods.” In summary, Sims concluded the program “could cause widespread foreclosure, abandonment and removal of affordable rental housing in the City of Los Angeles.” Silvern concluded the volume of repair activity which would be generated by the program could significantly affect the environment through the transportation, use and disturbance “of potentially toxic and/or hazardous materials (e.g., pesticides, asbestos and lead paint,” by permanently or temporarily displacing tenants, and by causing “changes to buildings that are of historic value.” For these reasons, petitioners argued to the council, an EIR should be prepared.

Notwithstanding petitioners’ objections, the city approved the permanent code enforcement program after concluding it was exempt from the requirements for an “initial study” and EIR under CEQA. As it did with the interim program, the city filed a “notice of exemption” with respect to the permanent program.

Following adoption of the ordinance creating the permanent code enforcement program, petitioners filed a timely petition in the superior court for a writ of mandate nullifying the ordinance. The petition challenged the city’s finding the code enforcement program was exempt from environmental study under CEQA. Petitioners contended the program had the potential for significant environmental consequences and the city’s finding to the contrary was not supported by substantial evidence or the law.

The trial court disagreed with petitioners. The court noted the current program was virtually “the same project” as the interim program and that it had upheld the city’s finding the interim program was exempt from CEQA review in an action by these same petitioners raising the same issues. Because the two programs were virtually the same, the court held, an EIR was not required as to the current program unless “new information of substantial importance, which could not have been known with the exercise of reasonable diligence at the time of the previous [finding] is discovered.” The declarations by the urban planners, Sims and Silvern, were not properly *1167 before the city council, the court ruled, because there was no showing why they could not have been produced at the time the council considered the interim program. Therefore, the court found petitioners failed to produce any “new” evidence in opposition to the program. The court further held even if the experts’ declarations were considered, the record contained substantial evidence to support the city’s determination the project was exempt from CEQA review.

The trial court entered an order denying the petition for writ of mandate and petitioners filed a timely appeal.

Discussion

I. Background: CEQA’s Three-tiered Structure for Environmental Review.

An explanation of CEQA’s three-tiered structure for environmental review will aid in understanding the issues raised by the petitioners in this appeal.

If a project falls within a category exempted from environmental review by statute or administrative regulation, no further agency evaluation is required. 4 If the project is not categorically exempt, the agency undertakes an “initial study” of the project. 5 If this study demonstrates the project will not have a significant effect on the environment, the agency makes a “negative declaration” to that effect. 6 On the other hand, if the “initial study” determines the project may have a significant effect on the environment, an EIR is required. 7

In the present case, the city council determined the permanent code enforcement program was categorically exempt from environmental review under the state and city CEQA guidelines. 8 On the motion adopting the permanent program the council found: “[Tjhis project ... is categorically exempt from CEQA pursuant to Article VII, Section 1, Class 1, Category 4 of the City’s CEQA Guidelines because the effect of the project is the *1168 restoration or rehabilitation of deteriorated or damaged structures, facilities or mechanical equipment or systems to meet current standards of public health, safety or environmental protection[.]” The council further found the project is exempt under class 9, category 2 of the city’s CEQA guidelines “because the project would allow a City department to inspect the quality, health or safety of a project[.]” And, finally, the council found “the project is exempt under Class 21, Category (a) of the State CEQA Guidelines because it is the enforcement of a law administered or adopted by the regulatory agency[.]” 9

Having found the project exempt from further review, the city did not undertake an “initial study” or issue a negative declaration or EIR.

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Cite This Page — Counsel Stack

Bluebook (online)
109 Cal. Rptr. 2d 504, 90 Cal. App. 4th 1162, Counsel Stack Legal Research, https://law.counselstack.com/opinion/apartment-assn-of-greater-los-angeles-v-city-of-los-angeles-calctapp-2001.