Santa Clarita Organization for Planning the Environment v. County of Los Angeles
California Court of Appeal
131 Cal. Rptr. 2d 186 (2003)
Los Angeles County (defendant) prepared an environmental-impact report (EIR) for a large mixed-use development, West Creek, estimating its water demand and describing the area's water supply by referencing the developers' entitlements to State Water Project water. Those entitlements were based on a planned capacity of 4.23 million acre-feet per year, but the State Water Project had never been fully built and actually delivered only 2 to 2.5 million acre-feet annually. After a public comment noted there was no guarantee the full entitlements would ever be received, the County merely revised the EIR to note that future demand might exceed supply, and certified the report; the Santa Clarita Organization for Planning the Environment (plaintiff) petitioned for a writ of mandate challenging the EIR's adequacy, which the trial court denied.
Whether an environmental-impact report must inform the public and responsible officials of the environmental consequences of a decision before it is made, including the cumulative impact of past, present, and future projects.