Cleveland National Forest Foundation v. County of San Diego

Two local environmental organizations challenged San Diego County’s approval of a “Forest Conservation Initiative Amendment” to the County’s general plan. The Amendment applied to more than 70,000 acres of the Cleveland National Forest. The petitioners alleged that the Amendment would have “devastating, long-term consequences” for San Diego’s backcountry and would result in increased greenhouse gas emissions. They asserted that the County had failed to comply with the California Environmental Quality Act (CEQA), including by improperly relying on guidance issued in July 2016 to conduct the analysis of greenhouse gas impacts instead of relying on thresholds set forth in a legally adequate Climate Action Plan (which the County had not adopted). They also asserted that the County’s analysis had relied on statewide per-person greenhouse gas goals necessary to achieve statewide goals, “without substantial evidence that they are relevant to projects in San Diego County” and that the environmental impact report (EIR) did not provide substantial evidence to support the emissions disclosed. In addition, the petitioners said that the County had failed to adopt feasible mitigation measures to address the Amendment’s significant greenhouse gas impacts. The petitioners further alleged that the Amendment violated the California Planning and Zoning Law because it was inconsistent with the County’s general plan, which required that evaluation of greenhouse gas impacts be based on a Climate Action Plan.