Save Our Heritage Organisation v. City of San Diego

*660 I

INTRODUCTION

Save Our Heritage Organisation (SOHO) appeals from a judgment denying its petition for writ of mandamus challenging the approval by the City of San Diego (City) of an environmental impact report (EIR) addendum for revisions to the Plaza de Panama project (project) at Balboa Park. SOHO contends we must reverse the judgment because the City's approval of the addendum violated the California Environmental Quality Act (CEQA; Pub. Resources Code, § 21000 et seq. ) 1 in two respects. First, SOHO contends CEQA Guidelines section 15164 (Guideline 15164), 2 which authorizes the addendum process utilized by the City, is invalid because *234 CEQA contains no authority for the addendum process and the addendum process conflicts with CEQA's public review requirements. Second, SOHO contends the City approved the project revisions without making new findings under section 21081.

We conclude SOHO has not met its burden of establishing the addendum process is invalid. We further conclude the City was not required to make findings under section 21081. We, therefore, affirm the judgment.

*661 II

BACKGROUND

This case has a lengthy record and litigation history. We summarize…