Our previous post on the Second District Court of Appeal’s decision in Center for Biological Diversity v. Department of Fish & Wildlife, No. B245141 (Mar. 20, 2014), highlighted the court’s holdings on California Environmental Quality Act (CEQA) and California Endangered Species Act (CESA) issues. The opinion also provides a useful (although unpublished) discussion on how to evaluate the significance of a project’s greenhouse gas (GHG) emissions under CEQA. This post examines the court’s GHG analysis, and adds observations regarding the California Air Resources Board’s (CARB) May 22, 2014 adoption of the First Update to the AB 32 Scoping Plan (Updated Scoping Plan).
Continue Reading Is A 16% Reduction in GHG Emissions From “Business-As-Usual” Enough Under CEQA?