Joaquin Raptor Rescue Center v. County of Merced

In Joaquin Raptor Rescue Center v. County of Merced (2007) 149 Cal.App.4th 645, the EIR required "a management plan" to be prepared "by a qualified biologist to 'maintain the integrity and mosaic of the vernal pool habitat.' " (Id. at p. 669.) The court held that this measure was deficient because it merely included a "generalized goal of maintaining the integrity of the vernal pool habitats," placing the onus of mitigation on the future plan and leaving the public "in the dark about what land management steps will be taken, or what specific criteria or performance standard will be met ... ." (Id. at p. 670.)