NEW CEQA CASE: “Flexible” Traffic Standards Under General Plan Do Not Establish Level Of Significance Criteria For Purposes of Environmental Analysis.

In East Sacramento Partnership for a Livable City v. City of Sacramento, (2016) 5 Cal.App.5th 281, petitioners challenged the City of East Sacramento’s certification of an EIR for a 336–unit residential development with a community recreation center and three parks on a 48.75–acre site.  The Court of Appeal held that: the EIR adequately disclosed development agreement; the project description was not defective; the EIR did not engage in improper piecemealing; BUT, the EIR provided an inadequate explanation for its conclusion that traffic impacts were not significant.