In Black Property Owners Assn. v. City of Berkeley (1994) 22 Cal.App.4th 974, 985, the City of Berkeley revised its housing element to include the possible construction of 747 additional housing units over 5 years. (Black Property Owners Assn. v. City of Berkeley, supra, 22 Cal.App.4th at p. 978.) Although no party disputed an initial study's conclusion that the new housing construction would have positive environmental effects, a property owners' association challenged the adoption of the housing element revision, alleging that the city should have been required to prepare an EIR on the adverse consequences of its housing policies in general. (Id. at pp. 978, 985 & fn. 7.) The appellate court held that because no changes were proposed to the city's housing-related ordinances, CEQA did not require any assessment of the ordinances' environmental effects. (Id. at p. 985.) Further, a rent control ordinance that was "ratified and acknowledged" in the housing element update was exempt from CEQA. (Id. at p. 986.) "To require an EIR on the policies embodied in the rent control ordinance, which was not subject to CEQA when it was enacted 13 years ago by the voters of Berkeley, and which Berkeley has taken no action to change, would not further" the statutory purpose of CEQA. (Ibid.) In Black Property Owners Assn. v. City of Berkeley (1994) nonprofit property owner associations challenged the City of Berkeley's compliance with CEQA in updating the housing element of its general plan as statutorily mandated. (Id. at p. 978.) "The City conducted an initial study under CEQA to determine whether an EIR was necessary because the draft update contemplated possible construction of 747 additional housing units between 1990 and 1995. The initial study indicated that this new construction would not result in adverse environmental effects and would instead have beneficial effects. Based on this study, a negative declaration was prepared." (Ibid.) The appellate court recognized: "Because general plans embody fundamental land use decisions that guide future growth and development of cities and counties, they have the potential for resulting in ultimate physical changes in the environment. ... When a proposed amendment to a general plan is the subject of an initial study, in most cases the agency will not be required to assess the environmental effects of the entire plan or preexisting land use designations. Instead, the question is the potential impact on the existing environment of changes in the plan which are embodied in the amendment. " (Black Property Owners Assn. v. City of Berkeley, supra, 22 Cal.App.4th at p. 985.) The appellate court determined the City of Berkeley had complied with CEQA in that instance and "the City's acknowledgment of its existing housing-related ordinances in its update was not an aspect of the project necessitating environmental review." (Black Property Owners Assn. v. City of Berkeley, supra, 22 Cal.App.4th at p. 986.) It explained: "Because the revision was a project as defined by CEQA and the possibility existed that it might have a significant effect on the environment, the City conducted the necessary initial study. Consistent with its duty to assess the effects on the physical environment of any proposed changes in the element, the initial study analyzed the potential impact of the contemplated new housing construction and concluded that beneficial environmental effects would result. Fn. omitted. Because no changes were proposed in the housing-related ordinances, no assessment of their environmental effect was required by CEQA." (Id. at p. 985.)