What isn't clear about this case is how the CBA requirement arose in the first place, i.e. whether the county imposed the CBA requirement in response to community concerns about the project, or whether the county put the CBA requirement in the master plan in order to hold the developer to promises that it had made (I'll be checking into this). It's also not clear what the county had in mind when it made the CBA requirement. The minutes of the board of supervisors from December 16, 2006 (just prior to the master plan approval), simply state that "[t]he applicant shall enter into a Community Benefits Agreement that commits them [sic] to a series of benefits that are specific to the nature of the project and the needs of the local community." There's no indication as to whether the county expects the developer to negotiate with community groups or local officials about these benefits. It's also unclear how extensive the benefits have to be.
Still, even if the scope of the CBA is presently unknown, it's good news for CBA supporters that the court rejected the EIR due to the fact that the CBA hadn't yet been completed. CBA provisions may indeed be important to the environmental review of the project. However, this case may not supply persuasive precedent for future cases involving CBAs that aren't required by the municipality.