## Facts

- A regional planning agency adopted a long-range regional transportation plan and sustainable communities strategy projecting transportation and land-use investments through 2050.
- The accompanying environmental impact report (EIR) analyzed greenhouse gas (GHG) emissions for multiple future years, acknowledged an executive order setting a 2050 statewide emissions-reduction goal, and disclosed that projected post-2020 emissions would not follow that long-term reduction trajectory.
- Environmental and community organizations, joined by the state Attorney General, challenged the EIR under the California Environmental Quality Act (CEQA), arguing the EIR inadequately evaluated and addressed long-term GHG impacts and related mitigation, among other CEQA defects.
- The trial court issued a writ of mandate in part, concluding the EIR’s post-2020 GHG analysis and mitigation discussion were inadequate and setting aside the agency’s certification; it left other CEQA claims unresolved.
- The Court of Appeal affirmed, reasoning that the EIR was deficient for failing to analyze consistency with the executive order’s 2050 climate target.
- The Supreme Court granted review limited to whether CEQA required the EIR to treat the executive order’s 2050 target as the benchmark for significance and long-term GHG analysis.

## Issues

1. Whether CEQA required the agency to use the executive order’s 2050 GHG reduction goal as a CEQA significance threshold or benchmark for the EIR’s long-term GHG impacts.
2. Whether the agency abused its discretion by not discussing the executive order and its 2050 goal more extensively in evaluating long-term GHG impacts.

## Decision

- The Supreme Court reversed the Court of Appeal in part.
- The Court held that, when the EIR was prepared, the agency did not abuse its discretion by declining to adopt the executive order’s 2050 target as a CEQA significance threshold and by not providing a more extensive discussion of the order.
- The case was remanded for further proceedings consistent with the Supreme Court’s limited holding, leaving other CEQA issues outside the scope of the Court’s decision.

## Legal Principles

- CEQA review asks whether the agency proceeded as required by law and whether its determinations are supported by substantial evidence; courts do not reweigh environmental conclusions where the record reflects reasoned analysis supported by evidence.
- An executive order establishing statewide climate goals, without a translating statute, regulation, or binding statewide implementation framework applicable to the agency’s decision, is not automatically a mandatory CEQA significance threshold.
- CEQA does not compel a single, exclusive methodology for assessing long-term GHG significance in the absence of binding statewide standards; adequacy of GHG analysis is context-dependent and may change as climate regulation develops.
- Although not required on this record, agencies preparing EIRs should, where feasible and as governing policy becomes more concrete, relate long-term emissions trajectories to established state climate goals and regulatory requirements.

## Conclusion

The court held that CEQA did not, at the time of this EIR, require the regional planning agency to treat the Governor’s 2050 emissions-reduction target as the controlling threshold for significance or to expand its discussion of that target, and it reversed the appellate ruling to the extent it imposed that requirement while remanding for proceedings on remaining CEQA issues.


Cleveland Nat’l Forest Found. v. San Diego Ass’n of Gov’ts, 3 Cal. 5th 497 (Cal. 2017)