In Save Panoche Valley et al. v. San Benito County, the Sixth District Court of Appeal held that San Benito County had not violated the Williamson Act or the California Environmental Quality Act when it approved construction of a 420-megawatt solar project on land designated as “agricultural rangeland.” The court sided with the County on both claims, holding that there was substantial evidence showing that cancellation of Williamson Act contracts was justified because other public concerns substantially outweighed the Williamson Act’s goals of preserving agricultural land. The court further held that the County adequately considered feasible project site alternatives and that the final environmental impact report properly analyzed the project’s impacts. The court’s holding on the adequacy of agricultural mitigation measures to mitigate agricultural impacts to below a level of significance may represent a departure from previous cases around the state.
