Mission Bay Alliance v. Office of Community Investment and Infrastructure

A California Superior Court rejected challenges to the environmental review and approvals for a mixed-use development in San Francisco that featured a new arena for the Golden State Warriors. Among the arguments rejected by the court was a contention that a quantitative analysis of greenhouse gas emissions was required. The court noted that the lead agency had appropriately evaluated the project based on a local greenhouse gas strategy. The court also said that the California Environmental Quality Act (CEQA) did not require that project components considered in the greenhouse gas analysis be treated as mitigation measures. In response to the petitioners’ challenge to the project’s acquisition of greenhouse gas emissions offsets, the court noted that the project sponsor had agreed to obtain the offsets (in order to be certified as an “Environmental Leadership Development Project,” in addition to complying with the local greenhouse gas strategy and that the commitment to purchase the offsets was further evidence that the project’s greenhouse gas emissions were not significant.