Cleveland Nat. Forest v. San Diego Assn. of Gov.

INTRODUCTION

After the San Diego Association of Governments (SANDAG) certified an

environmental impact report (EIR) for its 2050 Regional Transportation Plan/Sustainable

Communities Strategy (transportation plan), CREED-21 and Affordable Housing

Coalition of San Diego filed a petition for writ of mandate challenging the EIR's

adequacy under the California Environmental Quality Act (CEQA) (Pub. Resources

Code, § 21000 et seq.).1 Cleveland National Forest Foundation and the Center for

Biological Diversity filed a similar petition, in which Sierra Club and the People later

joined.

The superior court granted the petitions in part, finding the EIR failed to carry out

its role as an informational document because it did not analyze the inconsistency

Further statutory references are also to the Public Resources Code unless otherwise stated.

2 between the state's policy goals reflected in Executive Order S-3-05 (Executive Order)

and the transportation plan's greenhouse gas emissions impacts after 2020. The court

also found the EIR failed to adequately address mitigation measures for the transportation

plan's greenhouse gas emissions impacts. Given…