Amendment Of Specific Plan To Include Ban On New Vineyards Did Not Destabilize Project Description Under CEQA

A change from heavy regulation of vineyards to a complete ban on new vineyards did not so destabilize the original project description as to amount to a prejudicial abuse of discretion and require a new EIR. Gooden v. County of Los Angeles, 106 Cal.App.5th 1 (2024).

The land uses in the Santa Monica Mountains of Los Angeles County are regulated through the County's General Plan which include area plans. The land within the North Area Plan is primarily open space, with limited commercial and residential uses and only about 100 acres devoted to agriculture. In 2016, the County Board of Supervisors undertook a comprehensive update of the North Area Plan. The proposed updates discussed in the draft EIR included stricter regulations of vineyards, including lowering the threshold for requiring conditional use permits, but it did not contemplate a total ban. Petitioners argued that the Board's subsequent decision to ban new vineyards deviated so significantly from the