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San Diego Navy Broadway Complex Coalition v. San Diego, City of

ELR Citation: 40 ELR 20164
Nos. No. D055699, (Cal. App. 4th Dist., 06/17/2010)

A California appellate court held that a local development agency was not required to prepare a subsequent or supplemental environmental impact report (EIR) under the California Environmental Quality Act (CEQA) regarding the potential impact of a redevelopment project on global climate change. CEQA requires a public agency to prepare an EIR whenever the agency undertakes a discretionary project that may have a significant impact on the environment. The "touchstone" for determining whether an agency has undertaken such a discretionary action is whether the agency would be able to meaningfully address the environmental concerns that might be identified in the EIR. Here, the development agency lacks authority to address the project's impact on climate change. Environmental review would thus be a meaningless exercise.