Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova The California Supreme Court’s decision in Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (Vineyard) turns up the heat on the vexing question of how future water supply for proposed projects must be analyzed under the California Environmental

Quality Act (CEQA). Appellate courts recently had produced numerous and sometimes conflicting rulings regarding future water supply analysis under CEQA; Vineyard marks the first time the California Supreme Court has weighed in. Unfortunately, while the Court’s opinion provides some

clarity, it also muddies the waters in other respects.

The central issue in this debate and in Vineyard is how clearly future water supplies for a proposed project must be identified and assured in an environmental impact report (EIR) for a development project or land use plan – or, conversely, what level of uncertainty regarding the availability of water supplies is acceptable.