The California Environmental Quality Act (CEQA) requires government agencies in California to analyze and, when feasible, mitigate the environmental impacts of projects before approving them.  In Woodward Park Homeowners Association v. City of Fresno (PDF), the Court of Appeal recently held that CEQA does not automatically require projects with significant air quality or greenhouse gas impacts to include onsite solar panels as a mitigation measure. 

While the case is unpublished, it addresses a comment that is frequently raised in CEQA