ELR Citation: ELR 20004
No(s). S165861 (Cal. Dec 28, 2012)

The California Supreme Court held that a county's decision not to renew a conditional use permit for a private airport is not a "project" subject to environmental review under the California Environmental Quality Act (CEQA). Declining to renew the conditional use permit was not a public project under CEQA because the county did not "directly undertake" to close the airport. Instead, it decided not to reauthorize a private activity that required the issuance of a permit. The airport operation was the project in question, and projects rejected by a public agency are specifically exempted from CEQA requirements.