By Cori Badgley
In Sunset Sky Ranch Pilots Association v. County of Sacramento (2009) ___ Cal.4th ___ the California Supreme Court reversed the decision of the appellate court, which held that the denial of a conditional use permit renewal was a project under CEQA. Although project denials are generally exempted from CEQA review, the appellate court reasoned that in this case the result of denying renewal of the permit constituted the whole of the action, and therefore, CEQA applied. (See “Court Holds that County Has Power to Deny Conditional Use Permit Renewal, but CEQA Applies”.) The California Supreme Court disagreed.