City of Livermore v. Local Agency Formation Commission

The City of Livermore sued the Alameda County Local Agency Formation Commission (LAFCO), seeking to prevent LAFCO from implementing the revised sphere of influence guidelines it adopted in 1983. Livermore claimed: (1) that under the California Environmental Quality Act (CEQA) (Pub. Resources Code, § 21050 et seq.), LAFCO was required to prepare an environmental impact report (EIR) before it could adopt the new guidelines; and, (2) that the new guidelines conflicted with the Knox-Nisbet Act (Gov. Code, § 54773 et seq.). The Alameda County Superior Court enjoined LAFCO from implementing the guideline revisions, ruling that LAFCO had to prepare an EIR to analyze the environmental impact of the revisions and to show that the revisions complied with the Knox-Nisbet Act. LAFCO appeals this ruling.

Background

The Knox-Nisbet Act created local agency formation commissions for the purposes of discouraging urban sprawl, encouraging orderly formation and development, and coordinating the needs of local governmental agencies. (Gov. Code, § 54774.) To accomplish these goals, Knox-Nisbet directed local agency formation commissions to develop and determine a “sphere of influence” for…