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Sierra Club v. Napa County Board of Supervisors

ELR Citation: 42 ELR 20084
Nos. No. A130980, (Cal. Ct. App. 1st Dist., 04/20/2012)

A California appellate court upheld a county board's adoption of a zoning ordinance pertaining to lot line adjustments. The ordinance continued the county's existing administrative practice of allowing lot line adjustments impacting four or fewer parcels to readjust lots included in a prior application, provided the prior adjustments had been completed and recorded. The ordinance also continued existing policy and practice such that line adjustments are ministerial acts not subject to the California Environmental Quality Act (CEQA). An environmental group argued that the ordinance's provisions concerning sequential lot line adjustments—any readjustment of a parcel that had been previously adjusted in the past five years—violate the state's Subdivision Map Act. But the provisions are consistent with the Map Act's exemption for lot line adjustments. And because the ordinance spells out a ministerial lot line adjustment approval process, the ordinance is exempt from CEQA. Accordingly, the group's CEQA claim was dismissed as well.