2015 and 2016 Year2015 was a banner year for CEQA rulings by the California Supreme Court, with four decisions handed down, each of which addressed key issues in the application of the statute and its governing regulations: Berkeley Hillside clarified the application of the “unusual circumstances” exception to categorical exemptions; City of San Diego addressed the feasibility of offsite mitigation; Center for Biological Diversity set new parameters for analysis of greenhouse gas emissions; and CBIA confirmed that CEQA does not address the environment’s impact on a project.