In Placer Ranch Partners v. County of Placer, (2001) 111 Cal. Rptr. 2d 577, the California Court of Appeal upheld the County’s decision to prohibit residential development within a one-mile buffer around the County landfill, even though no scientific evidence was presented to support the one-mile width and no other jurisdictions require such a large buffer.
The decision grew out of the County’s adoption of a general plan update, which, among other changes, imposed the buffer and left that area within the buffer zoned only for agricultural and industrial uses. Placer Ranch Partners and other property owners affected by the decision (Developers) filed an action challenging the County’s decision, claiming that imposition of the buffer was not supported by the evidence.
The Court disagreed with the Developers’ argument. Factors the Court considered significant in support of the County’s decision included evidence that (1) the useful life of the landfill would be reduced by residential encroachment within the buffer; (2) residents from more than two miles away already had complained of dust, odor, litter, and traffic related to the current landfill; (3) the landfill site was flat and it could be seen from a distance, whereas other cases in which smaller buffer zones had been imposed involved much less highly visible facilities; and (4) none of the proposed buffer area currently was zoned for residential use, and other non-residential uses were allowed.
The County provided no scientific evidence to support its decision, and the Developers presented evidence that a 1,000- to 2,000-foot buffer was adequate and no other communities had required such a large buffer. The Court found, however, that the County’s evidence demonstrated the restriction imposed had a reasonable relation to the public welfare, and that whether a larger zone was necessary was “a fairly debatable question.” It therefore deferred to the County’s judgment, noting that setbacks and similar buffers are tools frequently used by local governments in the interest of sound community planning.
This case stands for the proposition that the courts will not disturb governmental land use decisions that are reasonable and rationally related to public welfare goals. When the issue is one where reasonable minds may disagree, the court will defer to the governmental agency’s decision.