While the presidential Primary Election will be a non-event in California,this upcoming Election Day, June 5, will be a relatively quiet one for land use measures in California as well. Only a handful of measures appear on city and county ballots. Perhaps not surprisingly, Orange County features two of the most contentious measures: one to promote affordable housing in Yorba Linda and to create a new commercial center in Cypress.

The trials of Sisyphus are apt metaphors for that moment in the California Environmental Quality Act review process wherein parties believe they have reached the summit but in fact discover themselves at the bottom of the hill, only to repeat their past efforts.

Muting one of the more burdensome requirements of the Subdivision Map Act, the First Appellate has ruled in favor of "multiple sequential adjustments" in Sierra Club v. Napa County Board of Supervisors. 

Observers of the California Environmental Quality Act may find it refreshing when a court lays it on the line. And that is exactly what Division Eight of the Second Appellate District did in addressing CEQA's requirements for baseline selection for projects with future implementation dates. Neighbors for Smart Rail v.