Position of Valencia

Valencia argues that (1) its WMP is not a "project" under CEQA; (2) even if it is a "project," the WMP is categorically exempted from CEQA review on the grounds it is "planning study"; (3) its WMP is statutorily exempt from CEQA under Water Code § 10652, which pertains to urban water management plans; and (4) Valencia's application is exempt from CEQA because this proceeding involves "rate setting," and is thus exempt under Public Resources Code Section 21080(b)(8).