Coca-Cola Bottling Co. v. Board of Estimate
This case concerns an Article 78 proceeding initiated by The Coca-Cola Bottling Company of New York, Inc. against the Board of Estimate of the City of New York and other city entities, along with Con-Agg Recycling Corp. Coca-Cola challenged the Board of Estimate's approval of Con-Agg's concrete recycling business in The Bronx and an amendment to the urban renewal plan, alleging violations of the State Environmental Quality Review Act (SEQRA). The core issue was whether the Department of Environmental Protection (DEP) or the Board of Estimate was the proper 'lead agency' responsible for assessing the environmental impact. The trial court and Appellate Division found that DEP's issuance of a conditional negative declaration, rather than the Board of Estimate making the final environmental policy decision, violated SEQRA. The Court of Appeals affirmed, holding that the 'lead agency' with principal responsibility for approving an action must also determine its significant environmental effect, and Mayoral Executive Order No. 91 was invalidly applied to the extent it diminished this responsibility.