8. California Environmental Quality Act (CEQA) Considerations
As noted above, Public Resources Code Section 21080 requires that we consider the environmental consequences of projects that are subject to our discretionary approval. The nature of the transaction, combined with assertions of the Applicants, assure us that "the proposed transaction is entirely a `paper' transaction."39 No authority for new construction is requested in the application.
We conclude that under these circumstances, the proposed project qualifies for an exemption from CEQA pursuant to § 15061(b)(3) of the CEQA guidelines, inasmuch as it can be seen with certainty that the project will have no significant impact upon the environment. Accordingly, the Commission need perform no further environmental review for this application.
39 Joint Application at 16.
