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On March 11, 2015, the California Supreme Court unanimously granted the San Diego Association of Governments’ (SANDAG) petition for review of the Fourth District Court of Appeal’s decision in Cleveland National Forest Foundation v. San Diego Association of Governments (2014) 180 Cal.Rptr.3d 548. A complete summary of the case is available here:, in which a majority of the three-judge panel held SANDAG was required to consider the consistency of its 2050 Regional Transportation Plan/Sustainable Communities Strategy with a 2005 executive order requiring a statewide reduction of greenhouse gas emissions.

The issue on appeal is limited to the following: “Must the environmental impact report for a regional transportation plan include an analysis of the plan’s consistency with the greenhouse gas emission reduction goals reflected in Executive Order No. 5-3-05 to comply with the California Environmental Quality Act?”

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