In Friends of the College of San Mateo Gardens v. San Mateo Community College District, No. S214061 (Cal. September 19, 2016), the California Supreme Court rejected the “new project” test for determining whether a changed project remains similar enough to the original project for supplemental CEQA review to be appropriate. Instead, the court created a different threshold inquiry for lead agencies, which asks whether the previous environmental document “retains any relevance” in light of changes to the project and whether “major revisions” to the previous environmental document are required. Unlike the “new project” determination, reviewed by a court de novo, the “retains relevance” inquiry gives judicial deference to the lead agency’s determination.