Working Families of Monterey County v. King City Planning Commission
(2024) (Case No. H051232)
California’s Sixth District Court of Appeal upheld the King City Planning Commission’s approval of a Grocery Outlet project, affirming its eligibility for an exemption under the California Environmental Quality Act (CEQA) Class 32 guidelines for infill development. The court rejected the appellants’ contentions that Class 32 exemption requires application of a population threshold and specific urbanized definitions. This case clarifies the scope of CEQA’s infill exemption and reinforces local discretion in land use determinations.
Background
In April 2021, Best Development Group (BDG) proposed a Grocery Outlet store in King City, filing for conditional use and related permits. The project site, previously used as a car sales lot, was located adjacent to Highway 101, surrounded by commercial properties, a cemetery, and public facilities.
The King City Planning Commission deemed the project exempt from CEQA under the Class 32 categorical exemption for infill development. The decision was affirmed by the King City Council after an appeal challenging the exemption’s applicability.
Working Families of Monterey County (Working Families) filed a writ of mandate alleging CEQA violations, contending that the exemption improperly applied due to King City’s rural character and the project’s insufficient environmental analysis.
Application of the Class 32 Exemption
Working Families argued that the City improperly applied the Class 32 exemption, contending the project did not meet the definition of an “urbanized area” as set forth in CEQA provisions requiring populations of 50,000 or 100,000, since King City’s population is only 13,332. They also asserted the project site failed to qualify as an “infill site” because it was not previously developed for “qualified urban uses.”
The City and BDG argued that the terms “qualified urban use,” “urbanized area,” and “infill site” are not part of the language of CEQA Guidelines section 15332, which governs the Class 32 exemption. They asserted that these terms appear in other CEQA provisions related to residential projects and cannot be read into section 15332, as their omission reflects the intended scope of the exemption.
They further contended that substantial evidence supported the City’s determination that the project site was “substantially surrounded by urban uses” under section 15332(b). Although the Guidelines do not define “urban uses,” they maintained that the City reasonably concluded, based on the environmental assessment, that the site was surrounded by urban development, including commercial buildings, a cemetery, the sheriff’s department, and a highway.
To determine whether the Class 32 categorical exemption for infill development applied to the Grocery Outlet project, the court analyzed the language of CEQA Guidelines section 15332. The court, applying traditional rules of statutory interpretation, emphasized that the plain language of regulations governs their interpretation unless ambiguity necessitates further analysis. In this case, the court found the language of section 15332 straightforward and declined to incorporate definitions from other CEQA provisions. The court noted that different terms used in various parts of CEQA suggest different meanings were intended, and the absence of specific definitions in section 15332 confirmed the regulators’ intent to apply the exemption broadly to appropriate projects.
To address the potentially ambiguous terms “in-fill development” and “substantially surrounded by urban uses” in section 15332, the court examined the intent of the Natural Resources Agency, which developed the regulation. During its drafting, the agency identified the primary purpose of the infill exemption as addressing urban sprawl. The exemption was designed to encourage development within existing urbanized areas, reduce reliance on vehicles, and preserve farmland, aligning with broader CEQA goals to mitigate environmental harm while supporting sustainable growth. The regulatory intent guided the court’s interpretation of section 15332, emphasizing its applicability to projects like the Grocery Outlet that fit within urban contexts, regardless of specific population thresholds.
Environmental Assessment Analysis
In addition to disputing the applicability of the Class 32 exemption, Working Families argued that the environmental assessment prepared for the project failed to adequately evaluate the impact of increased traffic on air quality, particularly the potential human health impacts to project users due to the project’s proximity to Interstate 101. The court declined to address this argument, underscoring that once a project qualifies for a categorical exemption under CEQA, it is not subject to further environmental review requirements, including the preparation of an environmental impact report.
Conclusion
The court’s decision in this case confirms that CEQA’s Class 32 exemption for infill development applies broadly without requiring the application of specific population thresholds or strict urbanized definitions. In doing so, this decision highlights the efficiency of the exemption process for appropriate infill projects and supports local agencies in making streamlined land use decisions.
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