Spring Valley Lake Association v. City of Victorville

The California Court of Appeal ruled that the environmental review for a shopping center in the City of Victorville did not comply with CEQA. The court found that substantial evidence did not support the City’s finding that the project was consistent with a provision of the general plan requiring new commercial and industrial projects to generate electricity on-site to the maximum extent feasible. The court also found that the record did not support a finding that the project would comply with the general plan’s energy efficiency objective and therefore did not support the City’s conclusion that the project would not have significant air quality impacts from greenhouse gas emissions.