Two Projects, 20 Years Apart, Constitute One CEQA Project

A court of appeal in California ruled that a decades-old plan to realign a road and a two-year-old plan to build a big box improvement store nearby only need to undergo one environmental impact analysis under the state's Environmental Quality Act.

2 minute read

November 29, 2007, 2:00 PM PST

By Nate Berg


"Development of a home improvement store and realignment of an adjacent road in Sonora constituted one project, and the combined activities should have been subject to a single environmental analysis, the Fifth District Court of Appeal has ruled."

"The fact that the road realignment appeared in the Sonora general plan 20 years before the Lowe's Home Improvement Warehouse was proposed and had been included in a local traffic impact fee program did not matter, the court determined. Instead, the court cited the close relationship between the proposed Lowe's and the road project, which was a condition of approval for Lowe's."

"In June 2005, the Sonora Planning Commission approved an 111,000-square-foot Lowe's building and 28,000-square-foot garden center, as well as a mitigated negative declaration for the development. One of the mitigation measures called for realignment and signalization of the intersection of Old Wards Ferry, Sanguinetti and Greenley roads, and relocation of the Sierra Railroad crossing of Old Wards Ferry. A group called Tuolumne Citizens for Responsible Development appealed to the City Council, which denied the appeal the following month."

"The citizens group then sued, alleging the city violated the California Environmental Quality Act (CEQA) in numerous ways. Tuolumne County Superior Court Judge James Boscoe ruled for the city and Lowe's. On appeal, the Fifth District overturned the lower court."

Note: California Planning and Development Report has made the source article accessible for free through Wednesday, December 5.

Thursday, November 29, 2007 in California Planning and Development Report

portrait of professional woman

I love the variety of courses, many practical, and all richly illustrated. They have inspired many ideas that I've applied in practice, and in my own teaching. Mary G., Urban Planner

I love the variety of courses, many practical, and all richly illustrated. They have inspired many ideas that I've applied in practice, and in my own teaching.

Mary G., Urban Planner

Use Code 25for25 at checkout for 25% off an annual plan!

Logo for Planetizen Federal Action Tracker with black and white image of U.S. Capitol with water ripple overlay.

Planetizen Federal Action Tracker

A weekly monitor of how Trump’s orders and actions are impacting planners and planning in America.

May 7, 2025 - Diana Ionescu

Person in yellow safety suit and white helmet kneels to examine water samples outdoors on a lake shore.

USGS Water Science Centers Targeted for Closure

If their work is suspended, states could lose a valuable resource for monitoring, understanding, and managing water resources.

May 1, 2025 - Inside Climate News

Wide suburban road with landscaped median and light pole banners advertising local amphitheater.

End Human Sacrifices to the Demanding Gods of Automobile Dependency and Sprawl

The U.S. has much higher traffic fatality rates than peer countries due to automobile dependency and sprawl. Better planning can reduce these human sacrifices.

April 29, 2025 - Todd Litman

Wasco Viaduct under construction in California's Central Valley as part of California High-Speed Rail project.

Trump: Federal Government Won’t Pay for California HSR

The President has targeted federal funding for the California bullet train project since his first administration.

May 8 - The Fresno Bee

Bird's eye view of Salesforce Park in San Francisco, CA.

San Francisco Enhances Urban Planning Initiatives with Green Infrastructure

San Francisco incorporates green infrastructure in its city development initiatives, elevating the importance of sustainability in urban planning.

May 8 - The Daily Californian

Aerial view of Chicago with river in foreground.

Chicago Approves Green Affordable Housing Plan

The Mayor’s plan calls for creating a nonprofit housing corporation tasked with building affordable housing that meets Green Building standards.

May 8 - CBS News Chicago

Urban Design for Planners 1: Software Tools

This six-course series explores essential urban design concepts using open source software and equips planners with the tools they need to participate fully in the urban design process.

Planning for Universal Design

Learn the tools for implementing Universal Design in planning regulations.

Comprehensive Bikeway Design Workshop

Transportation Research & Education Center (TREC) at Portland State University

Early Bird Deadline – save on your tuition fee!🚨

Institute for Housing and Urban Development Studies (IHS)