Transportation Solutions Defense & Education Fund v. California Air Resources Board

Petitioner challenged the California Air Resources Board’s (CARB’s) approval of the First Update to the Climate Change Scoping Plan (Update) and CARB’s certification of a program-level environmental assessment for the Update. Petitioner claimed that CARB violated both the California Environmental Quality Act (CEQA) and the Global Warming Solutions Act of 2006 (AB 32). In particular, petitioner alleged that CARB had failed to take into account the greenhouse gas emissions associated with the high-speed rail project included in the Update, that CARB violated CEQA procedures, and that inclusion of the high-speed rail project violated AB 32.