Riverwatch v. County of San Diego

(1999) 76 Cal.App.4th 1428

The Court of Appeal held that the final EIR approved by the County of San Diego complied with CEQA because it contained sufficient information on the impacts of both a proposed rock quarry and a road widening. The court rejected a citizen group’s argument that the EIR was deficient because it deferred until a later point more detailed environmental analysis. Although the extent of mitigation depended upon the future analysis, the EIR’s conclusion that the impact could be successfully mitigated was based on sufficient information. The court also held that the EIR’s baseline did not have to account for allegations of prior illegal activity that occurred at or near the vicinity of the project. [RMM Counsel of record: Tina A. Thomas]