A recent court decision provides guidance to lead agencies seeking to comply with CEQA requirements related to greenhouse gas (GHG) emissions. In Tsakopoulos Investments, LLC v. County of Sacramento, the Third District Court of Appeal held that sector-specific thresholds of significance for GHG emissions that are based on local emissions data are a model of CEQA-compliant significance thresholds. Specifically, the court upheld the GHG impacts analysis in an Environmental Impact Report (EIR) prepared for a mixed-use master planned community because the County of Sacramento relied on county-specific and sector-specific significance thresholds, rather than on statewide GHG emission reduction standards to evaluate the significance of project emissions.
The challenged project was the Mather South Community Master Plan, an urban growth project in Sacramento County that would result in thousands of residential dwelling units, public parks, schools and commercial retail spaces. The County of Sacramento certified the EIR for the project in...
