Catch-All Provision In County Application Checklist Violated Permit Streamlining Act

A Court of Appeal held that a provision in the County of Amador's checklist for an encroachment permit requiring "[o]ther information as may be required" violated the Permit Streamlining Act. Old Golden Oaks LLC v. County of Amador, 111 Cal.App.5th 794 (2025). However, the court found that the County's grading permit application checklist was sufficient to justify its determination that the developer's application was incomplete.

Petitioner applied for an encroachment permit and a grading permit to grade over 50,000 cubic yards for a residential subdivision. The County deemed both applications incomplete and requested several additional items, including wastewater treatment designs, a water agency plan, an indemnity agreement and "information necessary to comply with CEQA." Petitioner sued, arguing that the request for information not listed on the County's official checklists violated the Permit Streamlining Act (Gov't Code section 65920 et seq., the "PSA").