Citizens of Goleta Valley v. Board of Supervisors

In Citizens of Goleta Valley v. Board of Supervisors (1988) 197 Cal. App. 3d 1167, the court examined whether an EIR was required to include alternate sites as project alternatives. (197 Cal. App. 3d at p. 1178.) The developer of the project claimed that because it owned the proposed project site and there were no other feasible sites in the general area, no site alternatives were required. (Id. at p. 1179.) The court found "no authority or rationale for an inflexible rule that the availability of other sites must be considered . . . . It is necessary to examine the particular situation presented to determine whether the availability of other feasible sites must be considered in the EIR." (Ibid.) In the case before it, the court found that the developer's ownership of the proposed project site was a "factor of lesser significance." (Ibid.) In addition, because of the potential environmental impacts of the proposed project, reason required that the EIR at least consider the availability of feasible alternative sites. (Id. at p. 1180.)