Cleveland National Forest Foundation, Plaintiffs and Appellants v. San Diego Association of Governments Et…

Summary

The court held that SANDAG did not abuse its discretion under CEQA by declining to use the 2050 greenhouse-gas-reduction goal in the executive order as a formal significance threshold or to provide a more extensive consistency analysis. The EIR adequately disclosed projected greenhouse-gas increases, discussed the executive-order goal, and used three complementary analytical methods that sufficiently informed the public and decision makers. The court emphasized that its holding was narrow and that future EIRs must keep pace with evolving scientific knowledge and regulatory requirements.