A California state court has determined that the Environmental Impact Report (EIR), prepared in connection with approval of development in the Santa Clarita area, was not adequate to support the project’s approval. SCOPE v. City of Santa Clarita, No. BS 132487, (Cal. Super. Ct. 4/29/13). The plaintiff environmental groups had attacked the environmental report, asserting a variety of procedural and substantive errors in its creation. The court agreed that in at least two respects the EIR failed to meet the requirements of the California Environmental Quality Act (CEQA). First, the court found that the cumulative effects of the proposed project were analyzed inappropriately by looking at the relevant watershed rather than some smaller area, such as the river affected by the proposed project. According to the court, “It is manifestly improper to analyze the biological and non-biological effects of this .3 square mile project against the entirety of the 1,620-square-rnlle watershed.” The court also found the EIR faulty because it cited other documents without describing how they relate to the EIR. In the court’s view, this was contrary to the CEQA Guidelines which call for an EIR to describe “the relationship between the incorporated part of the referenced document and the EIR.”