Val Verde Civic Association v. County of Los Angeles

The California Court of Appeal affirmed the denial of a petition challenging the County of Los Angeles’s approval of a master plan revision for continued and expanded operations at the Chiquita Canyon Landfill. The court found that the petitioner had not argued in the Superior Court that the environmental impact report failed to quantify or analyze existing landfill emissions, and so had forfeited that argument. The appellate court also found that substantial evidence supported the methodologies used for data on criteria air pollutants and odors, as well as the methodologies used to determine landfill gas capture efficiency rates and to quantify greenhouse gas emissions, which relied on modeled data.