Friends of the Santa Clara River v. County of Los Angeles

A California Court of Appeal upheld the environmental review and land use approvals for a portion of Newhall Ranch, a major commercial and residential development in Los Angeles County. In an unpublished opinion, the court approved the selection of a greenhouse gas emissions significance criterion that was based on the emissions reductions goal in the California Global Warming Solutions Act of 2006, which required adoption of a statewide plan to reduce greenhouse gas emissions to 1990 emissions levels by 2020. The appellate court noted that three other appellate court cases had approved use of significance criteria based on this mandate. The court rejected the argument that this criterion was “illusory” and that the use of a “business-as-usual” emissions baseline was legally impermissible—but noted that the California Supreme Court wascurrently considering the baseline issue in Center for Biological Diversity v. Department of Fish and Wildlife, another case concerning the CEQA review for Newhall Ranch.