In Davidon Homes v. City of San Jose (1997) 54 Cal.App.4th 106, a city invoked the common-sense exemption to authorize a geological study of a foothill area, the second phase of which "required invasive testing techniques, including deep borings and installation of inclinometers" (54 Cal.App.4th at p. 109), and the appellate court found no shifting of the burden: "In this case the city's action was supported only by a conclusory recital in the preamble of the ordinance that the project was exempt under Guidelines section 15061, subdivision (b)(3). There is no indication that any preliminary environmental review was conducted before the exemption decision was made. The agency produced no evidence to support its decision and we find no mention of CEQA in the various staff reports. A determination which has the effect of dispensing with further environmental review at the earliest possible stage requires something more. We conclude the agency's exemption determination must be supported by evidence in the record demonstrating that the agency considered possible environmental impacts in reaching its decision." (Davidon Homes, supra, at pp. 116-117.) The problem there was that an ordinance, on its face, authorized "invasive testing techniques, including deep borings and installation of inclinometers" (Davidon Homes, supra, 54 Cal.App.4th at p. 109), on hillside areas that studies showed were "underlain with deep-seated, active landslides" ( id. at p. 119). It thus appeared "that the required testing would result in some physical changes in the environment," and the appellant's argument of resultant "noise, dust and visual impacts on surrounding residents, wildlife, and plantlife" "on its face was therefore not outside the realm of common sense." ( Id. at p. 118.) The court held, "The agency's exemption determination must be supported by evidence in the record demonstrating that the agency considered possible environmental impacts in reaching its decision" ( id. at p. 117), but it also stressed: "We do not agree with appellant that any possibility of an environmental impact, however remote or outlandish, will be sufficient in every case to remove a project from exempt status under Guidelines section 15061, subdivision (b)(3). That would render the common sense exemption meaningless." ( Id. at p. 118.)