Neighbors for Smart Rail v. Exposition Metro Line Construction Authority

A California appellate court affirmed a ruling that held that a public authority responsible for constructing a light rail line connection downtown Los Angeles with Santa Monica did not violate the California Environmental Quality Act (CEQA) when it analyzed the impact of the project on, among other things, greenhouse gas emissions using as a baseline conditions projected for 2030. The court rejected the notion that CEQA forbids, as a matter of law, the use of projected conditions as a baseline. The petitioners had argued that CEQA required the authority to use baseline conditions that existed sometime when the notice of preparation of the construction phase was filed in 2007 and when the authority certified the final environmental impact report in 2010. The appellate court disagreed, holding that that the project would not begin operating until 2015 at the earliest and thus its impact would yield no practical information to decision makers or the public until that time.