California, United States of America
The following excerpt is from Clews Land & Livestock, LLC v. City of San Diego, 19 Cal.App.5th 161, 227 Cal.Rptr.3d 413 (Cal. App. 2017):
An EIR must be prepared "[i]f there is substantial evidence, in light of the whole record before the lead agency, that the project may have a significant effect on the environment...." ( 21080, subd. (d).) " May means a reasonable possibility." ( Pocket Protectors v. City Of Sacramento (2004) 124 Cal.App.4th 903, 927, 21 Cal.Rptr.3d 791 ( Pocket Protectors ).)
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