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In CBD v. CDFW, the Court overturned the Newhall Ranch EIR, because it lacked substantial evidence to support the conclusion that a specific development project’s achievement of the Scoping Plan’s statewide average reduction goal below “business as usual” (BAU) was sufficient to determine the individual project’s GHG emission to be less than significant. CEQA approaches for GHG analysis are rapidly evolving, because of this decision, recent executive orders, and policy updates. Analysis approaches are also being explored by others. A goal of this paper is to contribute to the ongoing dialogue about how CEQA practice would respond to this evolution.

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