Sierra Club v. Co. of San Diego
Annotate this CaseIn 2011, San Diego County updated its general plan wherein it issued a program environmental impact report (PEIR), and adopted various related mitigation measures. The Sierra Club sought, in a petition for writ of mandate, to enforce one mitigation measure adopted by the County, the Climate Change Mitigation Measure CC-1.2: the preparation of a climate change action plan with "more detailed greenhouse gas [GHG] emissions reduction [GHG] targets and deadlines" and "comprehensive and enforceable GHG emissions reductions measures that will achieve" specified quantities of GHG reductions by the year 2020. However, the Sierra Club alleged that instead of preparing a climate change action plan that included comprehensive and enforceable GHG emission reduction measures that would achieve GHG reductions by 2020, the County prepared a climate action plan (CAP) as a plan-level document that expressly "does not ensure reductions." The County also developed associated guidelines for determining significance (Thresholds). The court granted the petition, concluding that the County's CAP did not comply with the requirements of Mitigation Measure CC-1.2 and thus violated CEQA. The court found that the CAP did not contain enforceable GHG reduction measures that would achieve the specified emissions reductions. The County appealed, asserting: (1) the statute of limitations barred the claim that the mitigation measures were not enforceable; (2) the CAP met the requirements of Mitigation Measure CC-1.2; and (3) that the trial court erred in finding that a supplemental EIR was required. Finding no reversible error, the Court of Appeal affirmed.
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