California, United States of America
The following excerpt is from Cleveland Nat'l Forest Found. v. San Diego Ass'n of Gov'ts, 180 Cal.Rptr.3d 548, 231 Cal.App.4th 1056 (Cal. App. 2014):
Lotus v. Department of Trans portation, supra, 223 Cal.App.4th at p. 656 & fn. 8, 167 Cal.Rptr.3d 382.) Thus, it is questionable whether these measures even qualify as mitigation measures.
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