A 2008 California Supreme Court decision, Save Tara v. City of West Hollywood, cast doubt on local governments’ ability to enter into agreements with private developers prior to completing project review under the California Environmental Quality Act (CEQA). In a pair of recent decisions, the Fourth District Court of Appeal upheld a public-private partnership (P3) water project against two CEQA challenges. In the first case, the court found that an agreement among the private and public partners and another public agency was not an improper pre-CEQA commitment under Save Tara. Focusing on the agency’s reservation of discretion to reject or modify the project, the court took a practical approach which may be applied to a wide range of agreements between public agencies and private entities, including but not limited to P3s. In the second case, the court held that the public partner properly acted as CEQA lead agency, notwithstanding its interest in the P3 project.