Environmental Council of Sacramento v. County of Sacramento

The California Court of Appeal upheld approvals for a large master-planned community in Sacramento County that included residential and commercial uses and a university campus. The petitioners contended that the university was not likely to be built, and that the environmental impact report (EIR) prepared under the California Environmental Quality Act (CEQA) was therefore insufficient because it failed to analyze the project without the university and thereby understated impacts, including climate change impacts. The appellate court found that the EIR adequately discussed greenhouse gas impacts, noting that a mitigation measure required that any revised use of the land meet a specified per-capita greenhouse gas emissions threshold. The court also rejected a claim that Sacramento County was required to consider the project’s consistency with the sustainable communities strategy prepared by the Sacramento Area Council of Government pursuant to SB 375 to reduce vehicle miles traveled and related greenhouse gases.