Cal. Sup. Ct.;
S217763

The California Supreme Court reversed a court of appeal judgment and remanded for further proceedings. The court held that the environmental impact report for a large-scale mixed use real estate development relied on an appropriate criterion of significance regarding greenhouse gas emissions, namely whether the project was consistent with meeting statewide emission reduction goals. The court held further, however, that the report’s finding of no significance was not supported by substantial evidence. The court also held that the report erred by imposing biological resource mitigation measures that called for trapping and transplanting a fully protected fish species.