Grasping the nettle that has recently troubled other courts, the California Supreme Court on December 17, 1976, ambitiously set out the factors that should govern judicial review of controlled-growth ordinances in a decision upholding a city's residential building moratorium. Associated Home Builders of the Greater Eastbay, Inc. v. City of Livermore¹ involved a challenge to an initiative ordinance enacted by the voters of Livermore which prohibits issuance of residential building permits until local educational, sewage disposal, and water supply facilities comply with certain standards. The ordinance, which will totally prohibit development in the short run, is a logical extension of other recently litigated municipal ordinances that have allowed "phased" or sequential growth. Controlled growth plans have come under substantial scrutiny and attack in recent years, but to date no court has been willing to elaborate the proper scope of judicial review of such ordinances when they are based on a community's desire to protect its rural setting from the environmental depredations of increasing urbanization. Livermore may, by providing for consideration of the equitable housing responsibilities of particular municipalities in the context of regional needs, pave the way for more rational environmental planning in the land use arena by regional and state authorities.