Government Code Section 21167(f) Was Basis For Reduction.
In San Diego Citizenry Group v. County of San Diego, Case No. D059962 (4th Dist., Div. 1 July 30, 2011) (unpublished), losing CEQA plaintiff did challenge the costs of preparing part of an administrative record and argued the County was not entitled to reimbursement of $6,067.94 for planning commission hearing transcripts not put before the County in the EIR approval process.
Plaintiff won this reduction. Based on Government Code section 21167(f), this was properly taxed based on a “reasonableness” standard–the planning commission hearings transcripts were not part of the “history of the project” because they occurred after County obtained approval of the EIR. Properly reduced, held the appellate court.