§ 15378, subd. (a)(1).); see also 235 Cal.App.3d at pp. 781-782 Stand Tall, supra, [concluding the school district’s contingent campus site selection was not a project because it was nothing like the project examples in the CEQA Guidelines].) (2007) 147 Friends of the Sierra Railroad v. Tuolumne Park & Recreation Dist. Cal.App.4th 643 (Sierra is instructive. In that case, an organization filed a Railroad) CEQA action to void a park district’s transfer of a right-of-way to an Indian tribe, arguing the transfer was a under CEQA and therefore the district was required to “project” prepare an EIR before finalizing the transfer. (Sierra at p. 647.) The appellate Railroad, court concluded the transfer was not a project because some development of “although the property surrounding the historical resource was review of reasonably foreseeable, conceivable impacts on the historical resource itself would have been premature in the absence of any (Ibid., italics added.) concrete development proposals.” The acknowledged there were many indications in the administrative record that the tribe intended to do with the acquired right-of-way. The tribe owned something the land surrounding the right-of-way and was in the process of building on it a hotel, commercial development, and residential homes. (Sierra 147 Railroad, supra, Cal.App.4th at p. 649.) The tribe had even told the county planning commission in a letter that it to use the right-of-way public hiking trails.” (Ibid.) “propose[d]” “for However, the court concluded the sheer of development” resulting from some “likelihood a land transfer not trigger CEQA review.” (Id. at p. 657.) The court acknowledged “does is no reason why CEQA review cannot be triggered by a transfer of ownership “[t]here
§ 15378, subd. (a)(1).); see also Stand Tall, supra, 235 Cal.App.3d at pp. 781-782 [concluding the school district’s contingent campus site selection was not a project because it was nothing like the project examples in the CEQA Guidelines].) Friends of the Sierra Railroad v. Tuolumne Park & Recreation Dist. (2007) 147 Cal.App.4th 643 (Sierra Railroad) is instructive. In that case, an organization filed a CEQA action to void a park district’s transfer of a right-of-way to an Indian tribe, arguing the transfer was a “project” under CEQA and therefore the district was required to prepare an EIR before finalizing the transfer. (Sierra Railroad, at p. 647.) The appellate court concluded the transfer was not a project because “although some development of the property surrounding the historical resource was reasonably foreseeable, review of conceivable impacts on the historical resource itself would have been premature in the absence of any concrete development proposals.” (Ibid., italics added.) The acknowledged there were many indications in the administrative record that the tribe intended to do something with the acquired right-of-way. The tribe owned the land surrounding the right-of-way and was in the process of building on it a hotel, commercial development, and residential homes. (Sierra Railroad, supra, 147 Cal.App.4th at p. 649.) The tribe had even told the county planning commission in a letter that it “propose[d]” to use the right-of-way “for public hiking trails.” (Ibid.) However, the court concluded the sheer “likelihood of some development” resulting from a land transfer “does not trigger CEQA review.” (Id. at p. 657.) The court acknowledged “[t]here is no reason why CEQA review cannot be triggered by a transfer of ownership
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