Government agencies that appear to commit themselves to a project through a conditional agreement and funding must first complete a California Environmental Quality Act analysis, even if the actual project approval comes later, the state Supreme Court has ruled. The circumstances surrounding the agreement matters as much as the agreement itself, the court determined.
The court ruled unanimously that the City of West Hollywood violated CEQA by not preparing an environmental review for an affordable housing development prior to approving a conditional agreement to provide property and funding to a nonprofit housing developer.