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City of Pleasanton CEQA GHG Emissions Thresholds and Guidance Center for Biological Diversity v. California Department of Fish and Wildlife (Case No. 217763) The California Supreme Court's decision in the Center for Biological Diversity v. California Department of Fish and Wildlife case was published on November 30, 2015.This decision evaluated the methodology used to analyze GHG emissions in an EIR prepared for the Newhall Ranch development project that included approximately 20,885 dwelling units with 58,000 residents on 12,000 acres of undeveloped land in Los Angeles County.The EIR used a business-as-usual approach to evaluate whether the project would be consistent with the AB 32 Scoping Plan.The Court found there was insufficient evidence in the record of that project to explain how a project that reduces its GHG emissions by the same percentage as the business-as-usual reduction identified for the State to meet its Statewide targets supported a conclusion that project-level impacts were below the level of significance. The California Supreme Court suggested regulatory consistency as a pathway to compliance by stating that a lead agency might assess consistency with the State's GHG reduction goals by evaluating for compliance with regulations designed to reduce GHG emissions.This approach is consistent with CEQA Guidelines Section 15064.4(b),which provides that a determination of an impact is not cumulatively considerable to the extent to which the project complies with regulations or requirements implementing a Statewide, regional,or local plan to reduce or mitigate GHG emissions.The Court also found that a lead agency may rely on numerical and efficiency-based thresholds of significance for GHG emissions, if supported by substantial evidence. Golden Door Properties, LLC v. County of San Diego/Sierra Club, LLC v. County of San Diego (Case No. 072406) The Fourth District Court of Appeal decision in the Golden Door Properties, LLC v. County of San Diego case (published on September 28, 2018) evaluated the County of San Diego's 2016 Guidance Document's GHG efficiency metric,which establishes a generally applicable threshold of significance for proposed projects.The Court held that the County of San Diego is barred from using its 2016 Guidance Document's threshold of significance of 4.9 MT of CO2e per service person per year for GHG analysis.The Court stated that the document violated CEQA because it was not adopted formally by ordinance, rule, resolution,or regulation through a public review process per CEQA Guidelines Section 15064.7(b).The Court also found that the threshold was not supported by substantial evidence that adequately explained how a service population threshold derived from Statewide data could constitute an appropriate GHG metric to be used for all projects in unincorporated San Diego County. Nevertheless, lead agencies may make plan-or project-specific GHG emissions threshold determinations. 20