California Court of Appeal

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Sierra Club v. Co. of San Diego, D064243

Order granting plaintiff’s petition for writ of mandate to enforce a climate change mitigation measure (CCMM) adopted by defendant County related to its general plan environmental impact report (EIR) is affirmed, where: 1) the County’s climate action plan (CAP) did not comply with the requirements of the CCMM and thus violated the California Environmental Quality Act, as the CAP did not contain enforceable greenhouse gas reduction measures that would achieve the specified emissions reductions; and 2) under either the “substantial evidence” or “fair argument" standard of review, the trial court did not err in finding a supplemental EIR was required.

Appellate Information

  • Decided 11/26/2014
  • Published 11/26/2014


  • Nares


  • California Court of Appeal