On June 19, a California appellate court upheld LA County’s approval of a new 1,800 acre land-use plan, rejecting the argument that additional environmental assessment was warranted. The County approved the new plan as a “modification” to the existing 2015 Antelope Valley Area Plan, and stated that the changes weren’t significant enough to require an entire new EIR. The Center for Biological Diversity argued that the existing EIR was inadequate because it was not circulated for additional comments after the addition of the new land-use aspects, and no supplemental EIR was prepared. The court stated that it was “not persuaded that [the County] failed to proceed in the manner required by CEQA.”

The court pointed out that recirculation is only required when significant new information is added to an EIR, and that in this case the new information merely “clarified or amplified the previously circulated draft EIR.” Similarly, a full subsequent EIR was not required because there were no “substantial changes” or “new information” inherent in the updated project.

The case is Center for Biological Diversity v. County of Los Angeles et al., case number BS156932, in the Court of Appeal of the State of California, Second Appellate District, Division Five.

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