Environmental Council of Sacramento v. City of Elk Grove CA3

CourtCalifornia Court of Appeal
DecidedAugust 30, 2021
DocketC089384
StatusUnpublished

This text of Environmental Council of Sacramento v. City of Elk Grove CA3 (Environmental Council of Sacramento v. City of Elk Grove CA3) 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
Environmental Council of Sacramento v. City of Elk Grove CA3, (Cal. Ct. App. 2021).

Opinion

Filed 8/30/21 Environmental Council of Sacramento v. City of Elk Grove CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA THIRD APPELLATE DISTRICT (Sacramento) ----

ENVIRONMENTAL COUNCIL OF C089384 SACRAMENTO et al., (Super. Ct. No. Plaintiffs and Appellants, 34201880002937CUWMGDS)

v.

CITY OF ELK GROVE et al.,

Defendants and Respondents;

SOUZA ELK GROVE, LLC, et al.,

Real Parties in Interest and Respondents.

The California Environmental Quality Act (CEQA; Pub. Resources Code, § 21000 et seq.) generally requires public agencies to prepare a detailed statement of environmental impacts, known as an environmental impact report or EIR, before approving projects that may have a significant effect on the environment. After an

1 agency has finalized an EIR for a proposed project, that is typically the end of the environmental review process under CEQA. But not always. Agencies at times propose changes to a project after an EIR has been prepared and, relevant here, when those changes are “[s]ubstantial” and require “major revisions” of the EIR, the agency must then prepare a subsequent or supplemental EIR providing detailed information about the potential environmental impacts of the proposed changes. But absent those circumstances, an agency generally may change its EIR through an addendum. In this case, the City of Elk Grove (the City) proposed modifying an EIR it had prepared for the development of 1,200 acres of largely agricultural lands. In the initial EIR, the City concluded that the proposed development would destroy foraging habitat for the Swainson’s hawk, a species listed as threatened under California’s Endangered Species Act. To mitigate the impact, the City required the developer to acquire, before any site disturbance, replacement foraging habitat that the California Department of Fish and Wildlife found suitable. But years later, the developer asked the City to modify the EIR to add an alternative mitigation option that would allow it to acquire replacement foraging habitat at a ranch known as the Van Vleck Ranch. The City agreed to the request and, in an addendum, it found the proposed change would not trigger the need to prepare a subsequent or supplemental EIR. Appellants Environmental Council of Sacramento, Sierra Club, and Friend of Swainson’s Hawk (collectively Environmental Council) afterward challenged that decision, alleging the City’s decision was not supported by substantial evidence. But the trial court disagreed, and, on appeal, we now affirm. At bottom, Environmental Council’s arguments show that different experts disagreed about the mitigation value of the Van Vleck Ranch site. One appeared to find the site inadequate. Another found differently. But a disagreement among experts is not reason, in itself, to conclude an agency’s decision is not supported by substantial evidence. We thus reject

2 Environmental Council’s challenge to the City’s decision and affirm the trial court’s judgment in the City’s favor. BACKGROUND I Legal Background CEQA serves “to ensure that public agencies will consider the environmental consequences of discretionary projects they propose to carry out or approve.” (Stockton Citizens for Sensible Planning v. City of Stockton (2010) 48 Cal.4th 481, 488.) To that end, absent an exemption, an agency proposing to carry out or approve a project generally must conduct an initial study to determine “if the project may have a significant effect on the environment.” (CEQA Guidelines,1 § 15063, subd. (a).) Depending on the initial study’s findings, the agency must then prepare either an EIR, a mitigated negative declaration, or a negative declaration. If “there is no substantial evidence that the project or any of its aspects may cause a significant effect on the environment,” the agency need only prepare a negative declaration that “briefly describ[es] the reasons that a proposed project . . . will not have a significant effect on the environment.” (CEQA Guidelines, §§ 15063, subd. (b)(2), 15371.) If substantial evidence shows the project may in fact have a significant environmental effect, but the project applicant agrees to changes that would avoid or mitigate them to an insignificant level, then the agency may instead prepare a mitigated negative declaration. (CEQA Guidelines, § 15070, subd. (b).) And if substantial evidence shows the project may have a significant environmental effect and a mitigated negative declaration is inappropriate, then the agency must prepare an EIR providing detailed information about the project’s

1 California Code of Regulations, title 14, sections 15000-15387 are commonly referred to as the CEQA Guidelines. We use that shorthand here.

3 potential environmental impacts. (Pub. Resources Code, §§ 21100 [state agency requirements], 21151 [local agency requirements], 21061 [defining an EIR].) For many projects, the preparation of an EIR “is the end of the environmental review process. But like all things in life, project plans are subject to change. When such changes occur, [Public Resources Code] section 21166 provides that ‘no subsequent or supplemental environmental impact report shall be required’ unless at least one or more of the following occurs: (1) ‘[s]ubstantial changes are proposed in the project which will require major revisions of the environmental impact report,’ (2) there are ‘[s]ubstantial changes’ to the project’s circumstances that will require major revisions to the EIR, or (3) new information becomes available.” (Friends of College of San Mateo Gardens v. San Mateo County Community College Dist. (2016) 1 Cal.5th 937, 945 (Friends); see also CEQA Guidelines, §§ 15162, subd. (a) [describing when a subsequent or supplemental EIR is required], 15163 [describing the difference between a subsequent and a supplemental EIR].) Our focus in this case is on the first of these circumstances calling for a subsequent or supplemental EIR — that is, when “[s]ubstantial changes are proposed in the project which will require major revisions of the environmental impact report.” Agencies may propose project changes requiring revisions to an EIR, including an EIR’s mitigation measures, for a variety of reasons. In some situations, for example, an adopted mitigation measure for a project may prove to be impracticable or unworkable. In other situations, as another example, an agency and the project applicant may find a new mitigation measure would be superior to the one initially adopted. Each of these scenarios, and others more still, may lead an agency to decide to modify a mitigation measure in its EIR. But only some of these changes, as Public Resources Code section 21166 shows, require the preparation of a subsequent or supplemental EIR. Should an agency’s proposed change to a mitigation measure be “[s]ubstantial” and “require major revisions

4 of the [EIR],” then, per Public Resources Code section 21166, the agency must prepare a subsequent or supplemental EIR. But should an agency’s proposed change fall short of “requir[ing] major revisions of the [EIR],” then the agency need only prepare an addendum to the EIR. To proceed by an addendum, the agency must determine, based on substantial evidence in the record, “that project changes will not require ‘major revisions’ to its initial environmental document, such that no subsequent or supplemental EIR is required.” (Friends, supra, 1 Cal.5th at p. 953; see also CEQA Guidelines, § 15164, subd.

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Environmental Council of Sacramento v. City of Elk Grove CA3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/environmental-council-of-sacramento-v-city-of-elk-grove-ca3-calctapp-2021.