By Joshua T. Bledsoe and Christopher W. Garrett

In Friends of Oroville v. City of Oroville, 218 Cal. App. 4th 1352 (2013) (Friends of Oroville), the Court of Appeal of California, Third Appellate District, recently confirmed that analyzing a project’s greenhouse gas (GHG) emissions under the California Environmental Quality Act (CEQA) via a threshold-of-significance derived from California’s GHG emissions reduction goals is appropriate.[1]  However, the Court held that this threshold-of-significance was applied improperly and remanded the case to the trial court to grant the requested writ of mandate.  This case contains lessons for the analysis of GHG emissions under CEQA that project proponents should be sure to keep in mind.