South Feather Water and Power Agency v. North Yuba Water Dist. CA3

California Court of Appeal·Decided August 14, 2026·No. C104121·Unpublished

Opinion

Filed 8/14/26 South Feather Water and Power Agency v. North Yuba Water Dist. CA3 NOT TO BE PUBLISHED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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

(Sutter)

SOUTH FEATHER WATER AND POWER C104121 AGENCY, Plaintiff and Appellant, (Super. Ct. No.

CVCS21-0002073)

v.

NORTH YUBA WATER DISTRICT, Defendant and Respondent.

Plaintiff South Feather Water and Power Agency (South Feather) appeals after the trial court entered judgment in favor of defendant North Yuba Water District (North Yuba). South Feather argues: (1) an actual controversy exists between the parties justifying South Feather’s declaratory relief cause of action forcing North Yuba to truthfully notify it of actions North Yuba takes under the California Environmental Quality Act (Pub. Resources Code, § 21000 et seq.) (CEQA); and (2) North Yuba was in possession of and required to disclose records held by an independent contractor for the purposes of South Feather’s cause of action under the California Public Records Act (Gov. Code, § 7920.000 et seq.) (Records Act).

We conclude South Feather forfeited the theory for declaratory relief it argues on appeal because it failed to argue those grounds in the trial court. When viewing the arguments for declaratory relief South Feather made in the trial court, it is clear South

Feather linked its success on the declaratory relief cause of action to its success on its other CEQA causes of action. Thus, the trial court did not err by finding no controversy existed between the parties after the CEQA causes of action had been resolved. We also conclude South Feather’s appellate claim under the Records Act is not cognizable because South Feather failed to file a petition for issuance of an extraordinary writ within the statutorily prescribed time. (Gov. Code, § 7923.500.) Accordingly, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND In October 2019, South Feather made a request to North Yuba under Public Resources Code section 21092.2 to give South Feather CEQA notices and documents, as well as notices of ministerial actions and categorial exemptions, pertaining to the Forbestown Ditch Project. In February 2020, North Yuba approved plans and a notice of exemption under CEQA for the Oroleve Ditch Project, which had previously been a part of what South Feather believed was the Forbestown Ditch Project. North Yuba did not send notice of these actions, or actions related to the Forbestown Ditch Project, to South Feather. This caused South Feather to file a petition for writ of mandate and complaint for declaratory relief alleging five causes of action. The first three causes of action were for writ of mandate alleging North Yuba: (1) violated CEQA by approving a notice of exemption for the Oroleve Ditch Project; (2) violated CEQA by piecemealing the Oroleve Ditch Project from the Forbestown Ditch Project; and (3) violated CEQA by failing to provide South Feather with requested CEQA notices.

The fourth cause of action was for declaratory relief and presented “[a]s an alternative claim if [the trial c]ourt finds that [South Feather] cannot challenge [North Yuba]’s purported decision to approve the [Oroleve Ditch] Project due to untimeliness, or for any other reason.” Specifically, South Feather alleged, “[North Yuba] is engaged in a pattern and practice of refusing to provide [South Feather] notices and information legally required under CEQA.” Accordingly, “an actual controversy has arisen under Code of Civil Procedure section 1060 between [North Yuba] and [South Feather] in

relation to [North Yuba’s] procedural obligation under CEQA and concerning [North Yuba]’s obligations to respond to CEQA inquiries in a truthful manner.”

South Feather’s fifth cause of action was for writ of mandate based on North Yuba’s alleged violation of the Records Act. This cause of action was based on North Yuba’s assertion it was not in possession of further documents responding to South Feather’s Records Act request. When South Feather later received documents pursuant to a subpoena from North Yuba’s independent contractor, however, the records contained e-mails not included in North Yuba’s disclosure to South Feather.

Before trial, South Feather filed a brief arguing North Yuba failed to provide CEQA notices in a truthful manner as requested by South Feather and required by law, pointing to North Yuba’s conduct when (1) signing and adopting a notice of exemption for the Oroleve Ditch Project; (2) adopting a resolution referencing the notice of exemption; (3) posting the notice of exemption; (4) drafting an initial study/mitigated negative declaration for the Forbestown Ditch Project; (5) submitting the initial study/mitigated negative declaration to the state clearinghouse; and (6) communicating with South Feather’s counsel about the initial study/mitigated negative declaration. South Feather relied on North Yuba’s lack of notice when arguing its CEQA causes of action were timely and North Yuba should be estopped from asserting a statute of limitations argument. As its request for relief, South Feather argued the trial court should declare North Yuba’s approval of the Oroleve Ditch Project inconsistent with CEQA. It further requested the court rescind North Yuba’s actions pertaining to the Forbestown Ditch Project and order a full environmental impact report with adequate CEQA notice to South Feather for the entire project.

During the court trial, South Feather divided its claims into two classes of cases—

the CEQA case and the Records Act case. For the CEQA case, South Feather argued it had requested CEQA notices from North Yuba for the Forbestown Ditch Project, which North Yuba piecemealed into two projects that included the Oroleve Ditch Project. North

Yuba then failed to provide South Feather CEQA notices and gave South Feather misleading CEQA information regarding both the Oroleve Ditch Project and the Forbestown Ditch Project. In addition to North Yuba’s failure to notify South Feather of the notice of exemption for the Oroleve Ditch Project, South Feather noted that North Yuba also told South Feather it was preparing an environmental impact report for the Forbestown Ditch Project, but instead adopted a mitigated negative declaration without notifying South Feather of that action. South Feather argued North Yuba should be estopped from arguing South Feather’s CEQA causes of action were time-barred given North Yuba’s failure to provide South Feather with truthful CEQA notices.

In its proposed statement of decision, South Feather included findings that North Yuba failed to give adequate CEQA notice, which excused South Feather’s failure to timely challenge the Oroleve Ditch Project. As relief, South Feather’s proposed statement of decision vacated North Yuba’s notice of exemption for the Oroleve Ditch Project and ordered North Yuba to complete a full environmental impact report for the Forbestown Ditch Project, while considering the Oroleve Ditch Project in the environmental analysis. South Feather’s proposed statement of decision then ordered North Yuba to provide written notice to South Feather of any CEQA findings related to the Forbestown Ditch Project as the project was defined in a 2005 agreement between the parties.

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South Feather Water and Power Agency v. North Yuba Water Dist. CA3, (Cal. Ct. App. 2026).

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