California Clean Energy Committee v. County of Placer

In an unpublished opinion, the California Court of Appeal largely upheld Placer County’s approval of a plan to expand an existing ski resort at Lake Tahoe, but concluded that the approval was invalid under CEQA because the County failed to analyze wildfire evacuation risk. The court said that the petitioner had failed to establish CEQA violations related to any of the energy-related issues it raised—which included the energy impacts of increased snowmaking, energy conservation, transportation and equipment energy impacts, and renewable energy resources. The court also found that the petitioner had failed to exhaust administrative remedies regarding a claim that the environmental impact report did not contain substantial evidence to support the determination that carbon credits were not feasible mitigation measures.