In reviewing a project's consistency as part of an environmental review, a city need not comply with every single general plan policy so long as it concludes that most general plan policies are being followed, the Fourth District Court of Appeal has ruled.

In a case involving a proposed bridge and parking garage in Balboa Park, the appellate court also overruled a trial judge's ruling that the City of San Diego violated its own municipal code by concluding that there would be "no reasonable beneficial use" of the famed Plaza de Panama if the bridge project were not built.

The case involves a proposal to remove automobiles from the Plaza de Panama in order to avoid conflicts between pedestrians and automobiles. The proposal would include construction of a new bridge, the Centennial Bridge, that would connect the historic Cabrillo Bridge to a new underground parking garage south of the Plaza. 

The City of San Diego did not violate the California Environmental Quality Act when it used as a baseline situation conditions that existed after emergency repairs were made under a CEQA exemption, the Fourth District Court of Appeal. The plaintiffs had argued that the city used the post-emergency baseline as a way to avoid CEQA review of a larger project.

The ruling overturned a trial court's ruling, and was a defeat for perpetual plaintiffs' attorney Cory Briggs, who frequently files CEQA lawsuits against the City of San Diego. The only victory Briggs got on appeal was a refund of his client's $100 appeal fee charged by the city.

The California Supreme Court has accepted Cleveland National Forest Association v. SANDAG, the controversial case that raises the question of whether a governor's executive order must be taken into consideration in CEQA analysis.