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This is the final in our series of eAlerts on the Council of Environmental Quality's (CEQ) Phase 2 revisions to its National Environmental Policy Act (NEPA) regulations, published on May 1, 2024 (Final Rule).

A California appellate court decision establishes new boundaries for challenging groundwater sustainability plans under SGMA, potentially limiting judicial review scope while clarifying when courts should defer to the Department of Water Resources' technical expertise. The ruling addresses critical procedural questions about reverse validation actions and the application of primary jurisdiction doctrine in groundwater management disputes.