Environmental & Energy
Oct. 9, 2026
When ministerial approvals become discretionary under CEQA
A lot line adjustment is ordinarily exempt from CEQA as a ministerial approval. But as a recent appellate decision illustrates, a separate discretionary action can subject the entire project to CEQA review.
A lot line adjustment is ordinarily ministerial and exempt from review under the California Environmental Quality Act. What happens, however, when the approval also requires a separate action over which the agency has discretion?
In Steer v. Town of Los Gatos (Sept. 3, 2026, H053166) __ Cal.App.5th __ (Steer), a newly published 6th District Court of Appeal decision, that separate action was the town's acceptance of a property dedication for a new cul-de-sac. T...
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