Friends of the College of San Mateo Gardens v. San Mateo County Community College District

—To ensure that governmental agencies and the public are adequately informed about the environmental impact of public decisions, the California Environmental Quality Act (CEQA) (Pub. Resources Code, § 21000 et seq.) requires a lead agency {id., § 21067) to prepare an environmental impact report (EIR) before approving a new project that “may have a significant effect on the environment” {id., § 21151, subd. (a)). When changes are proposed to a project for which an EIR has already been prepared, the agency must prepare a subsequent or supplemental EIR only if the changes are “[sjubstantial” and require “major revisions” of the previous EIR. {Id., § 21166.) Guidelines promulgated by the state Natural Resources Agency (Resources Agency) (Cal. Code Regs., tit. 14, § 15000 et seq.; hereafter CEQA Guidelines) extend this subsequent review framework to projects for which a negative declaration was initially adopted, and no EIR prepared, because the agency had concluded the project would have no potentially significant environmental effects. (CEQA Guidelines, § 15162.)

In this case, a community college district proposed a district-wide facilities improvement plan that called for…