Court Denies Standing Under CEQA for Sole Purpose of Furthering Petitioner’s Commercial and Competitive Interests

In Regency Outdoor Advertising v. City of West Hollywood,  the court of appeal held that Regency Outdoor Advertising (“Regency”) did not have standing to assert a CEQA challenge to amendments to the city’s Sunset Boulevard Specific Plan because Regency could only demonstrate commercial and competitive interests in the litigation. The appellate court, affirming the trial court’s conclusion, found that Regency lacked standing because it had not suffered any environmental injury. The court determined that Regency challenged the amendment regarding permissible outdoor wall signs, simply to “promote its commercial or competitive interests.” Relying on Waste Management of Alameda County v. County of Alameda (2000) 79 Cal.App.4th 1223, the court determined that CEQA does not create standing to pursue these interests. CEQA petitioners must demonstrate an environmental injury over and above the injury to the general public. Regency could demonstrate no such injury here.