What is the standard for further environmental review under section 15168 of the California Environmental Review Act?

section 15168, subdivision (c)(2) allows agencies to limit future environmental review for later activities that are found to be within the scope of the program EIR." ( Latinos Unidos de Napa v. City of Napa (2013) 221 Cal.App.4th 192, 196 , 164 Cal.Rptr.3d 274.)

This court addressed a program EIR for a transit plan in May v. City of Milpitas (2013) 217 Cal.App.4th 1307, 13161317 , 159 Cal.Rptr.3d 310 ( May ) and stated the section 21166 standard for further environmental review where a program EIR has already been prepared. In May, this court determined that "[s]ection 21166, part of CEQA, provides: When an environmental impact report has been prepared for a project pursuant to this division, no subsequent or supplemental environmental impact report shall be required by the lead agency or by any responsible agency, unless one or more of the following events occurs: [] (a) Substantial changes are proposed in the project which will require major revisions of the environmental impact report. [] (b) Substantial changes occur with respect to the circumstances under which the project is being undertaken which will require major revisions in the environmental impact report. [] (c) New information, which was not known and could not have been known at the time the environmental impact report was certified as complete, becomes available. Where environmental review has been conducted through a program EIR, CEQA requires further review only in these limited circumstances. [Citations.]" ( May, supra, at pp. 13251326 , 159 Cal.Rptr.3d 310, italics added.)