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Tresch v. County of Sonoma Agricultural Preservation and Open Space Dist. Bd. of Directors
This appeal arises from the adoption by a conservation district of a resolution interpreting an existing conservation easement to permit the establishment of a wildlife preserve on agricultural land. The preserve was proposed in the environmental impact report (EIR) prepared for a neighboring quarry project, as one potential means of mitigating the impact of the quarry on certain protected species. However, neither the conservation district’s resolution nor the conditions attached to approval of the quarry’s EIR actually required that the preserve be established. We hold that under these circumstances, adoption of the resolution interpreting the easement did not constitute “approval of a project” within the meaning of the California Environmental Quality Act (CEQA) (Pub. Resources Code, §§ 21000 et seq.).[1] We therefore affirm the trial court’s dismissal of appellants’ petition challenging the resolution under CEQA, and seeking an injunction against the adoption of similar resolutions without prior CEQA review.

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