The Sixth District Court of Appeal, in Santa Rita Union School District v. City of Salinas (2023), 94 Cal.App.5th 298, reversed the lower court, finding that the City of Salinas’ (“City”) final programmatic environmental impact report (EIR) for the West Area Specific Plan (“Specific Plan” or “Project”) did not need to analyze the impacts of a speculative alternative scenario that opponents argued was likely to occur. Specifically, the court found that it was appropriate for the City to analyze the impacts of its proposed plan—which included proposed site for schools to support increases in population due to future residential development—even though the local school Districts argued that the schools would likely never be built.
The Specific Plan covered approximately 800 acres and proposed a development including 4,340 dwelling units to accommodate up to 15,928 new residents at full build-out in 20-30 years, as well as commercial development, parks and open space, and schools. The Specific Plan area included three elementary schools, one middle school, one high school, all located within the Santa Rita Union School District (SRUSD) and the Salinas Union High School District (SUHSD) (collectively, “Districts”). To comply with CEQA, the City prepared the Specific Plan EIR, which provided varying levels of specificity as to various elements of the Plan, depending on available information.
The EIR clarified that individual projects within the Specific Plan, including the schools, might...
