In Parchester Village Neighborhood Council v. City of Richmond, the California Court of Appeal recently held that the City of Richmond’s decision to enter into a Municipal Services Agreement (MSA) with a Native American tribe did not constitute a “project” requiring California Environmental Quality Act (CEQA) review, even though the agreement effectively committed the City to a particular course of action. Parchester helps to define the scope of Save Tara v. City of West Hollywood, in which the California Supreme Court held that an Environmental Impact Report (EIR) needed to be completed where the city had effectively committed to approving a senior housing development project, even though its agreement with the developer was ostensibly conditioned on compliance with CEQA.