## Facts

- San Diego approved interrelated land-use measures to implement the North City West planned community, including a planned district ordinance and the Carmel Valley precise plan and design element.
- The project contemplated converting about 4,286 acres of agricultural land into an urban community anticipated to house roughly 40,000 residents.
- The administrative process spanned many years and included consultant and staff reports addressing environmental and planning topics, along with extensive public hearings concerning growth management and “quality of life.”
- The record reflected acknowledgment of substantial regional environmental impacts associated with the project, along with competing social and economic considerations.
- Del Mar, a neighboring city, opposed the approvals and asserted that San Diego’s decisionmaking would impose significant regional burdens.

## Issues

1. Whether San Diego failed to comply with CEQA in reviewing and approving the North City West planning actions.
2. Whether the approvals were inconsistent with San Diego’s general plan and growth-management policies, constituting an abuse of discretion.
3. What scope of judicial review applies to a local government’s approval of a large development, including whether the challenged determinations were supported by substantial evidence.

## Decision

- The Court of Appeal affirmed the judgment denying Del Mar’s petition for writ of mandate and request for declaratory relief.
- The court held San Diego did not abuse its discretion in approving the challenged planning steps.
- The court concluded the trial court applied the correct legal standards and that substantial evidence supported the judgment upholding San Diego’s actions.
- The court accepted that, although adverse environmental impacts were expected, the approvals reflected a rational balancing of environmental, social, and economic considerations within the city’s lawful discretion.

## Legal Principles

- In reviewing CEQA and land-use determinations, courts do not reweigh policy choices or substitute their judgment for that of the local legislative body.
- Judicial review is limited to whether the agency proceeded in the manner required by law and whether its determinations are supported by substantial evidence in the administrative record.
- CEQA generally requires informed decisionmaking through environmental disclosure and consideration of feasible mitigation and alternatives; it does not categorically bar approval of projects with significant environmental effects.
- A local agency may approve a project with significant impacts if it makes the required findings (and, when applicable, overriding considerations) supported by substantial evidence.
- Local governments have broad discretion to balance environmental, social, and economic factors in planning, and a court will not overturn that balance absent arbitrary action or legal error.

## Conclusion

The court upheld San Diego’s approval of the North City West planning actions because the city’s process and determinations satisfied applicable legal requirements and were supported by substantial evidence, and Del Mar’s objections largely challenged the wisdom of the growth decision rather than its legality.


City of Del Mar v. City of San Diego, 133 Cal. App. 3d 401 (Cal. Ct. App. 1982)