In Committee for Green Foothills v. Santa Clara County Bd. of Supervisors (2010) 48 Cal.4th 32, the issue was whether the filing of an NOD, allegedly without any environmental review, triggered a 30-day statute of limitations or a 180-day statute of limitations under section 21167. (48 Cal.4th at p. 39.) The court held that "when an agency files an NOD for the approval of a subsequent activity to a program EIR, and, in accordance with section 21166 and Guidelines section 15168, no negative declaration or EIR has been prepared for the activity, section 21167, subdivision (e) appears to furnish the appropriate statute of limitations for challenges to the agency's action." (Id. at p. 56.) In that case, a group argued that a subsequent development agreement constituted a new "project" and the responsible agency approved this project without determining its environmental effects. (Committee for Green Foothills, supra, 48 Cal.4th at p. 45.) According to the group, these allegations brought the case within the ambit of the 180-day statute of limitations. (Ibid.) Rejecting this argument, the Supreme Court held that the development agreement was not a CEQA project being considered for initial approval. (Id. at p. 52.) Rather, the court explained that the development agreement was a subsequent activity encompassed within the original project. (Id. at pp. 43, 52.)