Sierra Club v. County of Sonoma
Opinion
Opinion
Strankman, J.
This appeal by real party in interest Syar Industries, Inc. (Syar) is from an order granting a petition for writ of mandate and directing the County of Sonoma (the County) to: (1) set aside its approval of an application by Syar to engage in terrace mining operations along the Russian River; and (2) require preparation of an environmental impact report (EIR) before any further approval of the project. Respondents are the Sierra Club, a California nonprofit corporation, and the Russian River Task Force, an unincorporated association.
The outcome of this appeal hinges on the standard of review applicable to the County’s actions under the California Environmental Quality Act (CEQA) (Pub. Resources Code, § 21000 et seq.). As we will discuss, we conclude that the proper test is whether the administrative record contains substantial evidence to support a fair argument that Syar’s proposed site-specific project may cause significant adverse effects on the environment that were not examined in a prior, more general program EIR. We also conclude that the record contains such substantial evidence and affirm the judgment.