In Tuolumne Jobs & Small Business Alliance v. Superior Court, (2014) 59 Cal.4th 1029, the California Supreme Court held that CEQA review is not required when a local government entity adopts a voter submitted land use initiative directly (and without the need for a public vote), just as CEQA review is not required before voters adopt an initiative at an election.
In Rominger v. County of Colusa, (2014) 229 Cal.App.4th 690, the court held that the approval of a tentative subdivision map was subject to CEQA review categorically – even if a specific development project was yet to be planned. The court further held that CEQA procedural errors (in this case, failure to post public notice of the County’s intent to adopt a mitigated negative declaration (MND) for the full 30 days) constituted abuse of discretions, but such errors are not grounds for reversal unless they are shown to be prejudicial. The court held that the 27-day notice period in this case was not prejudicial. Also, the court rejected arguments that an EIR (as opposed to an MND) was required to address potential agricultural, odor, noise, air quality, greenhouse gas and water supply impacts, but the court agreed that an EIR was required to address potential traffic issues.