How have courts interpreted the "small facilities" exemption?

Wollmer v. City of Berkeley (2011) 193 Cal.App.4th 1329, 13501352, 122 Cal.Rptr.3d 781, for example, the court titled one part of its opinion No Unusual Circumstances Preventing Categorical Exemption and then proceeded to find no substantial evidence of potential significant environmental effects. In Voices for Rural Living v. El Dorado Irrigation Dist. (2012) 209 Cal.App.4th 1096, 11081113, 147 Cal.Rptr.3d 480, the court concluded that a casino requiring a high volume of water usage was an unusual circumstance for a project within the small facilities exemption, and it then proceeded to find that such high-volume water usage presented the potential for significant environmental risks. Other courts have employed similar reasoning. (See Bloom v. McGurk (1994) 26 Cal.App.4th 1307, 13151316, 31 Cal.Rptr.2d 914 [existing facilities exemption applied to medical waste facility, and there were no unusual

[343 P.3d 866]

circumstances because the facility was located in an area zoned for heavy industry and not adjacent

[60 Cal.4th 1133]