CITIZENS v. MCCLOUD COMMUNITY SERVICES DISTRICT
Public Resources Code Sec. 21177(b), which requires that a citizen objecting to a project under CEQA do so during public comment period or prior to the close of public hearing to retain standing to challenge the project in court, did not bar action where local agency did not hold a public hearing within the meaning of the statute but merely an informational meeting on a tentative agreement, the approval of which it did not consider to be an approval of a project within the meaning of CEQA, and where no notice of determination was issued following the meeting. Agreement for development of natural resource that was conditional on subsequent CEQA review did not itself constitute a "project" within the meaning of CEQA.
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