Agreement for City Services to Proposed Tribal Casino is Not a Project under CEQA

The First District Court of Appeal ruled that the City of Richmond did not violate CEQA when it entered into a municipal services agreement (MSA) for a tribal casino proposed on unincorporated lands adjacent to the City. In Parchester Village Neighborhood Council v. City of Richmond, the court reversed a trial court decision and agreed with the City that the MSA was not a project under CEQA.

Consistent with Save Tara, this case analyzed the various factors surrounding the MSA to determine if it constituted a project approval requiring CEQA review. Local agencies should continue to examine development-related agreements in a larger context to ensure that CEQA review occurs at an appropriate stage of the overall development process and before the agency has committed to activities that could have a physical effect on the environment.

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