Neighbors for Smart Rail v. Exposition Metro Line Construction Authority
57 Cal. 4th 439
| Cal. | 2013Background
- CEQA challenge to Expo Phase 2 light-rail approval from Culver City to Santa Monica; operation to be by MTA.
- Neighbors for Smart Rail alleged EIR baselines used only 2030 future conditions for traffic and air quality, omitting existing conditions.
- EIR also alleged to inadequately mitigate spillover parking near planned stations.
- Expo Authority used 2030 as sole baseline for traffic/air quality; evaluated but did not analyze impacts on 2007 existing conditions.
- The Court of Appeal denied relief on most CEQA claims; Supreme Court affirmed, with majority agreeing on baseline issue but not on spillover parking concerns; construction started 2011 and expected operation began around 2015.
- EIR analyzed other environmental topics using existing baseline; construction-period impacts considered; project aims to reduce congestion and improve air quality in long term.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a future-conditions baseline may replace existing conditions as the sole baseline | Neighbors: baseline must be existing conditions | Expo/MTA: agency may use future baseline if justified by evidence | Yes, but only with substantial evidence showing existing-baseline would be uninformative or misleading |
| Adequacy of spillover parking mitigation measures | Mitigation not enforceable since dependent on municipalities | Mitigation feasible with MTA monitoring and cooperation of local agencies | Mitigation adequate and enforceable as incorporated into CEQA process |
Key Cases Cited
- Communities for a Better Environment v. South Coast Air Quality Management Dist., 48 Cal.4th 310 (2010) (baseline choice and realism in CEQA analysis)
- Sunnyvale West Neighborhood Assn. v. City of Sunnyvale City Council, 190 Cal.App.4th 1351 (2010) (future baseline not per se prohibited; need for existing-conditions discussion in some cases)
- Madera Oversight Coalition, Inc. v. County of Madera, 199 Cal.App.4th 48 (2011) (limits on using solely future baselines; discretion with substantial evidence)
- Pfeiffer v. City of Sunnyvale City Council, 200 Cal.App.4th 1552 (2011) (uses of multiple baselines; distinctions from Sunnyvale West)
- Cherry Valley Pass Acres & Neighbors v. City of Beaumont, 190 Cal.App.4th 316 (2010) (baselines vary with changing conditions; realism required)