The Fourth Appellate District affirmed a judgment. The court held that a citizen group’s cursory written objection to a city’s approval of an environmental impact report was insufficient to alert the city to the alleged deficiencies in the report.

In 1994 the City of San Diego approved Pardee Homes’s final environmental impact report (FEIR) for a proposed development. Four years later, the city’s water department prepared a water supply assessment (WSA), as required by the Water Code and the California Environmental Quality Act (CEQA). The WSA concluded water supplies would be sufficient to meet the development’s needs during a projected 20-year period.