Citizens for Environmental Responsibility v. State Ex Rel. 14th District Agricultural Ass'n

The trial court denied a petition for writ of mandate and complaint for declaratory and injunctive relief filed by appellants Citizens for Environmental Responsibility, Stop The Rodeo, and Eric Zamost, under the California Environmental Quality Act (CEQA). (Pub. Resources Code, § 21000 et seq.) Appellants claim the 14th District Agricultural Association and its board of directors (collectively District) violated CEQA by approving a notice of exemption (NOE) from environmental review for a rodeo held by real party in interest Stars of Justice, Inc., at the Santa Cruz County Fairground (Fairground) in Watsonville in October 2011. The exemption was pursuant to CEQA’s regulatory guidelines (Cal. Code Regs., tit. 14, § 15000 et seq. (hereafter Guidelines)) for a “Class 23” categorical exemption for “normal operations of existing facilities for public gatherings.” (Guidelines, § 15323). Appellants contend the exemption is inapplicable because (1) the rodeo project expressly included mitigation measures in the form of a manure management plan, in effect acknowledging potential environmental effects, and (2) the unusual circumstances exception to categorical exemptions applies…