The California Supreme Court granted review of the decision that invalidated the San Diego Association of Government’s (SANDAG) Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) and the accompanying Program EIR. We reported on the Court of Appeal decision, Cleveland National Forest Foundation v. San Diego Association of Governments, in the December Land Use Law Update. Click here to view. SANDAG’s RTP/SCS was the first plan approved under the Sustainable Communities and Climate Protection Act of 2008, or SB 375, as it is better known. Although the lower court decision addressed a number of issues, the sole question that will be before the Supreme Court is whether the environmental impact report for the RTP/SCS must include an analysis of the plan’s consistency with the greenhouse gas emission reduction goals reflected in Executive Order No. S-3-05. The executive order, issued by then Governor Schwarzenegger in 2005, called for GHG emissions to be reduced by 80% below 1990 levels by 2050. As review was just granted on March 11, 2015, it will be some time before the California Supreme Court renders a decision on this important CEQA issue.