Santa Barbara County Flower & Nursery Growers Ass'n v. County of Santa Barbara

The California Coastal Commission (Commission) directed the County of Santa Barbara (County) to submit a proposed amendment to its local coastal plan (LCP) concerning greenhouse development in the Carpintería Valley, together with an environmental assessment of such development. As its environmental assessment, the County prepared and processed an environmental impact report (EIR) in accordance with the California Environmental Quality Act (CEQA). (Pub. Resources Code, § 21000 et seq.) Santa Barbara Flower and Nursery Growers Association, Inc. (Association), challenged the adequacy of the EIR by filing a petition for writ of mandate.

After the petition was filed, the County realized that the EIR had been prepared unnecessarily because the approval of LCP amendments by the Commission is exempt from the EIR requirements of CEQA. (§§ 21080.5, 21080.9.) The County asserted the exemption as a defense to the petition.

The trial court denied the petition, agreeing with the County that the approval of the LCP amendment was exempt from EIR requirements. The court also concluded that the Association’s petition was premature because the Commission’s process for approving the LCP…