The California Court of Appeal affirmed a trial court judgment that San Diego County’s greenhouse gas mitigation measures for two housing developments were inadequate under CEQA. The appellate court found that the mitigation measures suffered from the same deficiencies that the court previously identified in 2020 in Golden Door Properties, LLC v. County of San Diego for mitigation measures included in EIR for the County’s Climate Action Plan: they lacked enforceable performance standards and they impermissibly delegated and deferred the determination of whether greenhouse gas offsets were real, permanent, verifiable, quantifiable, enforceable, and additional. The court did not weigh in on whether the mitigation measures were compliant with the County’s general plan update since the general plan’s greenhouse gas-related provisions remained in flux due to ongoing litigation and because the mitigation measures had already been deemed not to comply with CEQA.

Challenge to San Diego County's approval of residential developments, allegedly without complying with requirements for enforceable measures to mitigate greenhouse gas emissions.

Sierra Club v. County of San Diego

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California Court of Appeal Agreed that Greenhouse Gas Mitigation Measures for San Diego Housing Projects Were Inadequate

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Area of the economy in which actors engage in identical or related activities.

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A ban is a legal action that prevents the sale or supply of a product or service, or that recalls a product from the market. Examples are bans on SF6, greenwashing, fossil fuel advertisement or single-use plastics.

A target to reduce the prevalence of a greenhouse gas over a specific time frame

Either money or something of monetary value is transferred between two or more organisations, people or countries.

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A long-lived, colourless gas, chiefly emitted from fossil fuel combustion, deforestation and cement production.

Replacing technologies that burn fossil fuels directly with alternatives powered by electricity.

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California Court of Appeal Agreed that Greenhouse Gas Mitigation Measures for San Diego Housing Projects Were Inadequate

Target

Policy instrument

Risk

Renewable energy

Greenhouse gas

Economic sector

Adaptation/resilience

Finance