Even Where No Environmental Review Was Undertaken, 30-Day Statute of Limitations for CEQA Challenge Applies Whenever NOD is Filed

Earlier this month, in Committee for Green Foothills v. County of Santa Clara, the California Supreme Court considered the question, if a notice of determination ("NOD") has been filed, but an action alleges that no environmental review was undertaken, which statute of limitations applies: (1) the general 30-day limit on challenges following a notice, or (2) the longer 180-day period provided for a case alleging that no environmental determination was made (§ 21167, subd. (a)). The Court held that the filing of an NOD triggers a 30-day statute of limitations for all CEQA challenges to the decision announced in the notice. Read more here.