Golden Door Props., LLC v. Cnty. of San Diego

Good Law
238 Cal. Rptr. 3d 559·27 Cal. App. 5th 892
Court of Appeal of CaliforniaSeptember 28, 2018D072406; D072433California5,530 words

Opinion

Lead Opinion

Huffman, J.

I

INTRODUCTION

The County of San Diego (the County) challenges a peremptory writ of mandate and injunction, along with a judgment directing it to set aside and vacate the "2016 Climate Change Analysis Guidance Recommended Content and Format for Climate Change Analysis Reports in Support of CEQA Document" (the 2016 Guidance Document or Guidance Document) and prohibiting it from using the Guidance Document or the "Efficiency Metric" defined in it as part of its California Environmental Quality Act (CEQA) review of greenhouse gas (GHG) impacts for development proposals in unincorporated areas of San Diego County. The County contends the matter is not justiciable because it is not ripe and the Guidance Document does not establish a threshold of significance for use in environmental review, nor does its use violate CEQA. The County further contends its separate development of a Climate Action Plan (CAP) and threshold of significance is evidence the Guidance Document does not violate a previous *562 writ or use piecemeal environmental review. We disagree with the County and affirm the trial court writ and judgment in their entirety.

II

BACKGROUND

A. Legal Principles

In June 2005,…

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