Sierra Watch v. County of Placer

The California Court of Appeal rejected challenges to the analysis of the climate change impacts of a proposed resort in Olympic Valley but found certain other elements of the California Environmental Quality Act (CEQA) review for the project to be inadequate. Regarding the climate change analysis, the appellate court found that the County of Placer’s modification of the analysis in the final environmental impact report (EIR) in response to a California Supreme Court decision did not require recirculation of the EIR. The appellate court also rejected the argument that the County failed to reconsider climate change mitigation in light of the revised analysis in the final EIR. The court noted not only that the County had reconsidered mitigation measures but also that the project could no longer result in the emissions levels that might have warranted reconsideration of mitigation. The court found that the plaintiff forfeited two other climate change arguments.