Center for Biological Diversity v. County of Los Angeles

On December 1, 2021, a Los Angeles-based nonprofit organization and the company developing the proposed Centennial at Tejon Ranch multi-use development in Los Angeles County <a href="https://tejonranch.com/settlement-agreement-reached-in-centennial-lawsuit/">announced</a> a settlement pursuant to which the organization will drop its CEQA claims and the developer will implement climate change and wildfire resilience measures. The developer said it had committed to net-zero greenhouse gas emissions through a combination of on-site and off-site measures, and that it would install almost 30,000 electric vehicle chargers within and outside the community and provide incentives for purchase of 10,500 electric vehicles. The developer also committed to fund wildfire protection and prevention measures. A separate case brought by Center for Biological Diversity and California Native Plant Society remains pending.

In May 2019, the Center for Biological Diversity and California Native Plant Society filed a lawsuit challenging the environmental review for a development project on 12,323 acres on Los Angeles County’s border with Kern County. The project, which the petition called “a new, sprawl city,” would include 19,333 houses and 8.4 million square feet of commercial, industrial, and business park uses. The petitioners alleged that the project is “exactly the type of leapfrog sprawl development that climate legislation such as SB 375 sought to prevent” and that it would generate 75,000 new vehicle trips per day, with an average trip length of 45 miles. The petitioners contended that the greenhouse gas emissions generated by these trips “will be many orders of magnitude greater than those of a non-sprawl development and will hinder California's efforts to combat climate change.” They asserted, among other things, that the project’s greenhouse gas emissions were not adequately analyzed or mitigated in Los Angeles County’s California Environmental Quality Act review and that the project is inconsistent with the greenhouse gas goals of the Los Angeles County General Plan.

On June 26, 2025, the California Court of Appeals held that the environmental impact report (EIR) involved in the California Environmental Quality Act (CEQA) challenge to the County of Los Angeles’s approval of the 12,000-acre Centennial Specific Plan proposed by Tejon Ranchcorp (Tejon), was legally inadequate with respect to climate change impacts, specifically greenhouse gas emissions (GHGs) and wildfire risk. The court found that the County’s reliance on California's cap-and-trade program to offset the Centennial project’s estimated unmitigated GHG emissions was prejudicially misleading and unlawful under the CEQA. The EIR claimed the project would emit approximately 157,642 metric tons of greenhouse gas emissions annually. After deeming these emissions “significant,” the County proposed to mitigate 96% of them through the purchase of cap-and-trade allowances. However, the court found this approach improper because, although the cap-and-trade program regulates certain sectors such as energy and fuel suppliers, the Centennial project itself was not a “covered entity” under the program. As a result, relying on emissions reductions already required by law for other entities did not constitute valid CEQA mitigation. Further, the CEQA’s “additionality” requirement prohibits the use of emissions reductions that are already legally mandated for other entities to offset a project’s climate impacts. Mitigation measures must result in new, project-specific reductions rather than rely on reductions that are already accounted for under existing regulatory schemes. Consequently, by inappropriately applying cap-and-trade credits, the court held that the County understated the project’s climate impacts, thus violating the CEQA. As a result, the court mandated that the EIR be decertified until the GHG analysis is corrected. The court also affirmed the Superior Court’s finding that the EIR’s discussion of wildfire risks beyond the project site was legally deficient because it failed to adequately consider how the project could exacerbate off-site wildfire conditions. The EIR acknowledged on-site wildfire risks but offered only a one-paragraph discussion of off-site wildfire risks, failing to analyze the risk of new ignitions from off-site project infrastructure and failing to meaningfully reduce these off-site risks. This rendered the analysis prejudicially misleading, especially given the growing severity of wildfires linked to climate change in California. The court also rejected claims that the EIR violated CEQA with respect to wildlife movement, habitat connectivity, native vegetation loss, and failure to consider feasible project alternatives. It further rejected Tejon’s claim preclusion argument based on Climate Resolve’s settlement on similar grounds.