Communities for a Better Environment v. City of Richmond

A California state appellate court held that the environmental impact report (EIR) for upgrades to a refinery located in Richmond, California failed to consider the project’s greenhouse gas emissions impacts as required under the California Environmental Quality Act (CEQA). The decision affirmed the June 2009 decision by the lower court that the environmental assessment fell short of the requirements of CEQA. The appellate court found that the EIR merely proposed a generalized goal of no net increase in greenhouse gas emissions and then set out vaguely described future mitigation measures.  The court stated that greater specificity was required.