California Public Resources Code Section 21177(C) - Interpretation
In Garrison v. Board of Directors (1995) 36 Cal.App.4th 1670, the appellate court interpreted Public Resources Code section 21177, subdivision (c), to permit "an organization formed after approval of the project to seek judicial review as long as a member of the organization objected prior to project approval."
Public Resources Code section 21667 provides for the time for the commencement of a CEQA action or proceeding. Public Resources Code section 21177 provides: "b) No person shall maintain an action or proceeding unless that person objected to the approval of the project orally or in writing during the public comment period provided by this division or prior to the close of the public hearing on the project before the issuance of the notice of determination.
"(c) This section does not preclude any organization formed after the approval of a project from maintaining an action pursuant to Section 21167 if a member of that organization has complied with subdivision (b)."