Bay Area Citizens v. Association of Bay Area Governments (248 Cal. App. 4th 966, 2016)

Opinion

STEWART, J.

The primary issue raised by this appeal is whether the Bay Area agencies newly charged by state law with adopting a plan to reduce regional greenhouse gas emissions from cars and light trucks over the coming decades should have relied on emissions reductions already expected from preexisting statewide mandates to fulfill their statutory obligation, rather than adopting regional strategies to reduce emissions beyond those already expected from the statewide mandates. We conclude, as did the trial court, that the relevant agencies correctly declined to count statewide emissions reductions in developing their regional plan because doing so would have been inconsistent with the statute, including as interpreted by the state agency responsible for implementing California’s greenhouse gas emission laws.

In 2008, the Legislature enacted the Sustainable Communities and Climate Protection Act of 2008 (Sen. Bill No. 375 (2007-2008 Reg. Sess.)), which we refer to as Senate Bill 375. Senate Bill 375 is one in a series of executive, legislative and administrative measures enacted to reduce greenhouse gas emissions and their adverse effects on our climate. Prior measures empowered the State Air Resources Board (Board) to enact statewide mandates to reduce emissions, such as standards for vehicle technology and carbon content in fuel. Senate Bill 375 empowers the Board, after consideration of these previous statewide mandates and consultation with experts and regional planning bodies, to set targets for each of California’s regional planning agencies to reduce emissions from automobiles and light trucks in its region. Senate Bill 375 requires each regional agency, after engaging in an extensive planning process, to develop a sustainable community strategy to meet the Board’s targets using regional land use and transportation policies. Sustainable communities strategies are subject to environmental impact review under the California Environmental Quality Act (Pub. Resources Code, § 21000 et seq.; CEQA).

In 2010, the Board issued its greenhouse gas emissions reduction targets for the Bay Area region. The Board called for the Bay Area’s Metropolitan Transportation Commission (MTC) and the Association of Bay Area Governments (ABAG) (collectively, the Agencies) to develop regional land use and transportation strategies that would result in per capita percentage reductions in emissions of 7 percent by 2020 and 15 percent by 2035, as compared to emissions in 2005. The Board repeatedly indicated that these reductions were to be in addition to those expected from preexishng statewide mandates.

The Agencies prepared an update to the Bay Area’s regional transportation plan and their hrst sustainable communities strategy in “Plan Bay Area.” The Agencies outlined ways to reduce greenhouse gas emissions in the Bay Area region independent of the statewide mandates so as to meet or exceed the Board’s targets for the region. The Agencies engaged in a CEQA review of Plan Bay Area, issued a draft environmental impact report, received public comments and approved a hnal environmental impact report. Subsequently the Board accepted the Agencies’ determination that Plan Bay Area would meet the Board’s emission reduction targets for the Bay Area region.

Appellant Bay Area Citizens (Citizens) was critical of Plan Bay Area and offered an alternative plan of its own that counted on reductions expected from the preexisting statewide mandates. After Plan Bay Area was approved, Citizens hied a petihon for writ of mandate in Alameda County Superior Court challenging the Agencies’ environmental impact report for, and adoption of, the Plan. Cihzens argued the Agencies did not comply with CEQA because their environmental review erroneously failed to include emissions reductions expected from the statewide mandates in determining how to meet the Board’s Senate Bill 375 targets. Cihzens contended that neither Senate Bill 375 nor the Board prohibited the Agencies from counting on such reductions, and that the Agencies should have adopted, or at least considered, a Citizens-proposed alternative that relied on them to avoid what Citizens viewed as the “draconian” land use and transportation strategies comprising Plan Bay Area. The trial court, concluding that reliance on statewide mandates to meet the regional targets would constitute improper double counting not permitted by Senate Bill 375 or the Board, denied Citizens’ pehtion. This appeal followed.

Citizens repeats its arguments on appeal, and we, too, find them unconvincing. Citizens relies on the premise that the Legislature, via Senate Bill 375, launched a major new climate protection inihative requiring regional agencies to develop regional land use and transportation strategies through an elaborate planning process that in the end would be superfluous because the Agencies could meet the Board’s regional emissions reduction targets simply by invoking reductions already expected from preexishng statewide mandates. This interpretation makes no sense. And it is contradicted by Senate Bill 375’s emphasis on regional innovahons, the Legislature’s declarations and findings, and the Board’s contemporaneous construction of the statute. Further, even apart from the regional focus of Senate Bill 375 and the Legislature’s declarations and findings, the Legislature conferred on the Board broad discretion to develop targets and require regional agencies to meet them through regional planning. It was within the Board’s discretion to require regional agencies to achieve emissions reductions entirely through regional planning strategies so as to produce emissions reductions beyond those produced by statewide mandates. We also agree with the Attorney General, appearing as amicus curiae, that the Agencies’ environmental review was sufficient under CEQA regardless of what Senate Bill 375 and the Board required of the Agencies. For these reasons, we affirm the trial court’s denial of Citizens’ petition.

BACKGROUND

I.

Greenhouse Gas Emissions Reduction Laws and Regulations

In 1997, the Legislature enacted a law that requires each regional metropolitan planning organization (MPO) to prepare and adopt a regional transportation plan designed to achieve a coordinated and balanced regional transportation system. (Stats. 1997, ch. 622, § 24, p. 4405; Gov. Code, § 65080, subd. (a) (section 65080).) This regional transportation plan must be “action-oriented and pragmatic, considering both the short-term and long-term future” and must “present clear, concise policy guidance to local and state officials.” (§ 65080, subd. (a).)

Prior to 2008, a number of statutes and regulations were enacted to reduce greenhouse gas emissions on the statewide level, which we refer to as the “statewide mandates.” In 2008, the Legislature enacted Senate Bill 375. It requires each MPO, as part of its regional transportation plan, to adopt a “sustainable communities strategy.” In this sustainable communities strategy, each MPO must adopt regional land use and transportation strategies designed to meet, if feasible, regional greenhouse gas emissions reduction targets for 2020 and 2035 that the Board is given broad discretion to set.

In 2010, after receiving the required input from an expert advisory committee and the Agencies, the Board established greenhouse gas emissions reduction targets for the Bay Area region pursuant to Senate Bill 375. The Agencies then developed a sustainable communities strategy for the region, Plan Bay Area, and in 2013 conducted an environmental review of it pursuant to CEQA. The Agencies concluded that Plan Bay Area met the Board’s Senate Bill 375 targets and was environmentally acceptable, and adopted it. In 2014, the Board accepted the Agencies’ determination that Plan Bay Area would meet the Board’s Senate Bill 375 targets.

Citizens raises numerous issues related to the Agencies’ compliance with CEQA in reviewing the potential environmental impacts of Plan Bay Area, focusing on the Agencies’ sustainable communities strategy. At the center of all of Citizens’ arguments is its contention that the Agencies should have, but did not, include the greenhouse gas emissions reductions that are expected from the statewide mandates in determining how to meet the Board’s targets for the Bay Area region.

A. Statewide Mandates Leading Up to Senate Bill 375

In 2002, the Legislature enacted Assembly Bill No. 1493 (2001-2002 Reg. Sess.), also called the Pavley legislation for its author. It requires the Board to develop regulations designed to reduce greenhouse gas emissions from new passenger vehicles, light-duty trucks and noncommercial vehicles sold in California. (Health & Saf. Code, § 43018.5.) Subsequently, the Board adopted these regulations, known as Pavley I and Pavley II respectively. Together, Pavley I and Pavley II set statewide emissions reduction targets for new passenger vehicles and trucks from 2009 through 2025.

In 2005, then-Governor Arnold Schwarzenegger issued Executive Order No. S-3-05. It calls for an overall reduction of greenhouse gas emissions within California to 1990 levels by 2020 and to 80 percent below 1990 levels by 2050.

In 2006, the Legislature passed the California Global Warming Solutions Act of 2006 (Health & Saf. Code, § 38500 et seq.; see Assem. Bill No. 32 (2005-2006 Reg. Sess.), sometimes Assembly Bill 32) “California’s landmark legislation addressing global climate change” (Center for Biological Diversity v. Department of Fish & Wildlife (2015) 62 Cal.4th 204, 215 [195 Cal.Rptr.3d 247, 361 P.3d 342]). Like Executive Order No. S-3-05, Assembly Bill 32 mandates that the State’s greenhouse gas emissions be reduced to 1990 levels by 2020. (Health & Saf. Code, § 38550.) It designates the Board as the “agency charged with monitoring and regulating sources of emissions of greenhouse gases that cause global warming in order to reduce emissions of greenhouse gases.” (Id., § 38510.) It charges the Board with developing and implementing regulations “to achieve the maximum technologically feasible and cost-effective greenhouse gas emission reductions from sources or categories of sources, subject to the criteria and schedules set forth” in the law. (Id., § 38560.) The Board’s responsibilities include development on or before January 1, 2009, of a “scoping plan” to achieve these reductions, and the updating of that plan every five years. (Id., § 38561, subd. (a).)

In 2007, then-Governor Schwarzenegger issued Executive Order No. S-01-07. It calls for the reduction of the carbon density of California’s transportation fuels by at least 10 percent by 2020, and the Board’s development of a “Low Carbon Fuel Standard” (the Low Carbon Fuel Standard) and accompanying regulations for transportation fuel providers designed to ensure they meet this reduction schedule. (Governor’s Exec. Order No. S-01-07 (Jan. 18, 2007).)

As required by Assembly Bill 32, the Board issued a “Climate Change Scoping Plan” (Scoping Plan) in December 2008. The Scoping Plan called for greenhouse gas emissions reductions in the transportation, electricity, commercial and residential, industry, recycling and waste, agriculture and forest sectors, among others. It identified measures to reduce emissions by 30 percent, or 174 million metric tons, as compared to projected business-as-usual emissions levels of 596 million metric tons as of 2020. These included reductions of 31.7 million metric tons expected from Pavley’s vehicle technology standards, 15 million metric tons expected from the Low Carbon Fuel Standard, and an additional 5 million metric tons expected, preliminarily, from “local land use changes” implemented to meet the targets the Board was to set pursuant to Senate Bill 375. The Scoping Plan also included measures to “put the state on a path to meet the long-term 2050 goal of reducing California’s greenhouse gas emissions to 80 percent below 1990 levels.” As our colleagues in Division Three have characterized it, the Scoping Plan’s 2020 goal “is but a step towards achieving” the “longer term climate goal” set out in Executive Order No. S-3-05. (Association of Irritated Residents v. State Air Resources Bd. (2012) 206 Cal.App.4th 1487, 1496 [143 Cal.Rptr.3d 65] [affirming that the Board’s Scoping Plan and a supplemental analysis satisfied the requirements of Assent. Bill 32].)

In 2012, Governor Edmund G. Brown, Jr., issued Executive Order No. B-16-2012. It directs state entities to support and facilitate the rapid commercialization of zero-emission vehicles. The order outlines benchmarks for 2015, 2020 and 2025 related to establishing infrastructure to support and accommodate zero-emission vehicles, helping to get zero-emission vehicles to market and on the road, and increasing their use for public transportation and public use. It also establishes a goal of an 80 percent reduction of greenhouse gas emissions from the transportation sector in California by 2050 as compared to 1990 levels.

B. Senate Bill 375

As we have indicated, Senate Bill 375, enacted by the Legislature in 2008 and effective as of January 1, 2009 (Stats. 2008, ch. 728, p. 5065), requires that each MPO, as a part of its regional transportation plan, develop a sustainable communities strategy that consists of regional land use and transportation strategies designed to reduce its region’s greenhouse gas emissions. (Id., ch. 728, § 1, subd. (e), p. 5066.) Each MPO must strive to meet two regional emissions reduction targets for the automobile and light truck sectors set by the Board for each region, one to be achieved by 2020 and the other by 2035.

Senate Bill 375 required the Board to provide the greenhouse gas emissions reduction targets to the regions by September 30, 2010. (§ 65080, subd. (b)(2)(A).) Before doing so, the Board was required to appoint a “Regional Targets Advisory Committee” (Advisory Committee) to recommend factors and methodologies to be used in setting these targets. (§ 65080, subd. (b)(2)(A)(i).) The Board also was required to exchange technical information with, and consider target recommendations by, each MPO. (Id., subd. (b)(2)(A)(ii).)

Further, and particularly germane to this appeal, the Board was required to consider other measures that it had approved or planned to adopt that would reduce greenhouse gas emissions in the affected regions, including Pavley and the Low Carbon Fuel Standard. Specifically, Senate Bill 375 states that the Board ‘“[i]n establishing these [regional] targets,” ‘“shall take into account greenhouse gas emission reductions that will be achieved by improved vehicle emission standards [Pavley], changes in fuel composition [the Low Carbon Fuel Standard], and other measures [the Board] has approved that will reduce greenhouse gas emissions in the affected regions, and prospective measures [the Board] plans to adopt to reduce greenhouse gas emissions from other greenhouse gas emission sources” consistent with regulations promulgated pursuant to Assembly Bill 32. (§ 65080, subd. (b)(2)(A)(iii).) “[G]reen-house gas emission reduction targets may be expressed in gross tons, tons per capita, tons per household, or in any other metric deemed appropriate by the [Board].” (Id., subd. (b)(2)(A)(v).)

Senate Bill 375 also requires the Board to update its regional greenhouse gas reduction targets every eight years consistent with each MPO’s time frame for updating its regional transportation plan under federal law. The Board may revise these targets every four years, provided that it again considers the other measures that it has approved or plans to adopt that would reduce greenhouse gas emissions in the affected regions. (§ 65080, subd. (b)(2)(A)(iv).)

Senate Bill 375 requires that each MPO, once it receives its targets, prepare a sustainable communities strategy following certain guidelines. First, each MPO must develop strategies that take into account both housing and transportation. Specifically, an MPO must, among other things, (1) ‘“identify the general location of uses, residential densities, and building intensities within the region,” (2) “identify areas within the region sufficient to house all the population of the region, including all economic segments of the population, over the course of the planning period of the regional transportation plan taking into account net migration into the region, population growth, household formation and employment growth,” (3) “identify a transportation network to service the transportation needs of the region,” and (4) “set forth a forecasted development pattern for the region, which, when integrated with the transportation network, and other transportation measures and policies, will reduce the greenhouse gas emissions from automobiles and light trucks to achieve, if there is a feasible way to do so, the greenhouse gas emission reduction targets approved by [the Board].” (§ 65080, subd. (b)(2)(B)(i), (ii), (iv), (vii).)

Each MPO also must adopt a public participation plan for the development of a sustainable communities strategy. (§ 65080, subd. (b)(2)(F).) Before doing so, however, an MPO must submit a description to the Board “of the technical methodology it intends to use to estimate the greenhouse gas emissions from its sustainable communities strategy.” (Ibid.) The Board must respond “with written comments about the technical methodology, including specifically describing any aspects of that methodology it concludes will not yield accurate estimates of greenhouse gas emissions, and suggested remedies.” (Ibid.)

Before adopting a sustainable communities strategy, an MPO must “quantify the reduction in greenhouse gas emissions projected to be achieved by the sustainable communities strategy and set forth the difference, if any, between the amount of that reduction and the target for the region established by [the Board].” (§ 65080, subd. (b)(2)(H).) If there is no feasible way to meet the Board’s targets, an MPO must prepare an “alternative planning strategy.” (Id., subd. (b)(2)(I).)

After an MPO adopts a sustainable communities strategy, it must submit it to the Board for review. Its submission must include “the quantification of the greenhouse gas emission reductions the strategy would achieve and a description of the technical methodology used to obtain that result.” (§ 65080, subd. (b)(2)(J)(ii).) The Board’s review is limited “to acceptance or rejection of the [MPOJ’s determination that the strategy submitted would, if implemented, achieve the greenhouse gas emission reduction targets established by the [Board].” (Ibid.)

Finally, a sustainable communities strategy does not regulate land use and is not subject to state approval other than as prescribed. Nothing in a sustainable communities strategy is to “be interpreted as superseding the exercise of the land use authority of cities and counties within the region,” nor shall anything “require a city’s or county’s land use policies and regulations, including its general plan, to be consistent with the regional transportation plan.” (§ 65080, subd. (b)(2)(K).)

II.

The Agencies’ Development, Environmental Review and Adoption of Plan Bay Area

The Board’s final targets for the Bay Area region, which it adopted in September 2010, were a 7 percent per capita reduction in greenhouse gas emissions by 2020 and a 15 percent per capita reduction by 2035, both as compared to 2005 emissions levels. This was consistent with what the Agencies told the Board their planners thought should be the upper limits of the regional targets for the Bay Area.

The Agencies determined these targets could be met by the land use and transportation strategies outlined in Plan Bay Area. The Agencies planned for the Bay Area region’s growth to occur in a “Priority Development Area” framework. Priority Development Areas are transit-oriented, infill development opportunity areas within existing communities that local agencies expect will accommodate the majority of future development. Each Bay Area county and more than half of the Bay Area’s cities have at least one Priority Development Area. Plan Bay Area calls for Priority Development Areas to be nominated by local jurisdictions. Local jurisdictions may designate as Priority Development Areas neighborhoods that are served by at least one transit stop or station, are supported by local plans to provide a wider range of housing options, and include amenities and services to meet the day-to-day needs of residents in a pedestrian-friendly environment. ABAG reviews each nomination and makes a final determination about whether an area qualifies as a Priority Development Area.

The Agencies projected that the Priority Development Area framework, along with associated investments in public transit, would result in significant reduced vehicle miles traveled per capita and increased reliance on transit by 2040. These changes in passenger travel patterns, resulting from Plan Bay Area’s land use and transportation strategies, if implemented, were projected to reduce light-duty vehicle greenhouse gas emissions from 2005 levels by 10.3 percent per capita by 2020 and 16.4 percent per capita by 2035.

In June 2012, the Agencies, pursuant to CEQA guidelines, issued a notice of preparation of a draft environmental impact report (DEIR) for the proposed Plan Bay Area. They held five public meetings and gave various governmental and nongovernmental groups and individuals the opportunity to provide input. In April 2013, they released their DEIR for a public review.

The DEIR analyzed whether Plan Bay Area would result in any of 46 “environmental issues and concerns identified as possibly significant,” which were grouped into 14 issue areas (e.g., transportation, air quality, noise). Under the “Greenhouse Gases and Climate Change” issue area, the Agencies included a climate change impact analysis that assessed the potential for significant adverse impacts related to greenhouse gas emissions. The Agencies found that Plan Bay Area “would have a potentially significant adverse impact” if it:

“Criterion 1: Fail[ed] to reduce per capita passenger vehicle and light duty truck CO2 emissions by seven percent by 2020 and by 15 percent by 2035 as compared to 2005 baseline, per [Senate Bill] 375.

“Criterion 2: Resultfed] in a net increase in direct and indirect [greenhouse gas] emissions in 2040 [the last year of Plan Bay Area] when compared to existing conditions.

“Criterion 3: Substantially impede[d] attainment of goals set forth in Executive Order S-3-05 and Executive Order B-16-2012.”

The DEIR’s criterion 1 (Criterion 1) analysis considered whether Plan Bay Area would meet the Board’s Senate Bill 375 targets. Accordingly, consistent with the Board’s approach, the DEIR analyzed what reductions in automobile and light truck emissions would occur by 2020 and 2035, as compared to 2005. As already discussed, the Agencies projected that Plan Bay Area would result in a 10.2 percent reduction in per capita emissions from these vehicles by 2020 and a 16.4 percent reduction by 2035, exceeding the Board’s targets of seven percent and 15 percent, respectively. The Criterion 1 analysis, which related to meeting the Senate Bill 375 targets, stated that reductions from Pavley I’s vehicle technology standards and the Low Carbon Fuel Standard were not included in determining these emissions reductions.

However, the DEIR took Pavley I and the Low Carbon Fuel Standard into account in its criterion 2 (Criterion 2) analysis, which determined whether net greenhouse gas emissions reductions in the Bay Area would be achieved by 2040, the last year of Plan Bay Area, as compared to 2010 emissions, when considering emissions from all vehicle classes in the transportation sector, as well as from the electricity, natural gas, recycling and waste sectors. The year 2010 was used as the baseline year for this Criterion 2 analysis because that year provided “the most recent best data available for land use, transportation, and demographics.’”

The DEIR then took the analyses used for Criterion 1 and Criterion 2 and applied them in its criterion 3 (Criterion 3) analysis to determine “whether or not implementation of the proposed Plan would impede attainment of the identified [executive] orders and whether the Plan moves the region towards a downward trajectory of [greenhouse gas] emissions in 2050,” a year that was a focus of Executive Order No. S-3-05 and Executive Order No. B-16-2012. Thus, the DEIR’s Criterion 3 analysis also included consideration of Pavley I and the Low Carbon Fuel Standard.

The DEIR also included a chapter discussing five different project alternatives, including Plan Bay Area. These were (1) a “No Project” alternative; (2) the proposed Plan Bay Area, with its focus on growth in Priority Development Areas; (3) a “Transit Priority Focus” alternative with a focus on growth patterns primarily in the urban core by relying on transit priority project-eligible areas (rather than Priority Development Areas), which are areas with high-frequency transit service that are eligible for higher density development streamlining; (4) an “Enhanced Network of Communities” alternative that had more dispersed growth patterns than the proposed plan; and (5) an “Environmental Equity and Jobs” alternative that maximized affordable housing in high-opportunity urban and suburban areas through incentives and housing subsidies. The DEIR presented each alternative and discussed its potential impacts as compared to those of the proposed Plan Bay Area. The DEIR’s analysis of these alternatives included a comparison of their relative impacts regarding Criterion 1 (achieving the Board targets set pursuant to Sen. Bill 375), Criterion 2 (the state of direct and indirect greenhouse gas emissions in 2040 when compared to existing conditions), and Criterion 3 (the attainment of goals set forth in Exec. Order No. S-3-05 and Exec. Order No. B-16-2012 by 2050), the latter two analyses including consideration of Pavley I and the Low Carbon Fuel Standard.

During a 45-day public review period, the Agencies held three public hearings on the DEIR and nine on the draft Plan Bay Area. They received over 340 written comment letters and numerous oral comments during the public comment period, and continued to receive comments after its close. Citizens was critical of Plan Bay Area and asserted the Agencies should consider Citizens’ alternative plan, called the “Bay Area Citizens Transportation and Housing Alternative.” The Agencies responded to Citizens’ comments, but did not specifically analyze the impacts of Citizens’ alternative plan, instead stating that they had considered a reasonable range of alternatives and that many elements of Citizens’ alternative plan were included in the alternatives they had assessed.

The Agencies submitted their proposed Plan Bay Area to the Board for its technical review. In June 2013, the Board’s staff presented to the Board a draft technical evaluation of the Agencies’ greenhouse gas emissions reduction quantification in their proposed Plan. The staff stated that the Agencies had “appropriately not included [greenhouse gas] emissions reductions from the technology and fuel programs adopted by [the Board], such as the Low Carbon Fuel Standard and [Pavley].” The staff concluded preliminarily that Plan Bay Area would achieve the Board’s emissions reduction targets for the Bay Area region.

On July 18, 2013, the Agencies certified the FEIR, which contained relatively minor changes to the DEIR that did not alter the DEIR’s conclusions regarding significant environmental impacts or mitigation measures. The Agencies also adopted findings pursuant to CEQA and adopted Plan Bay Area.

The Agencies approved a “Statement of Overriding Considerations.” It asserted 13 considerations overriding the environmental effects Plan Bay Area would have, including that it met the Senate Bill 375 targets, was part of a “collaborative approach to development [that] provides the best opportunity to create a sustainable future for the Bay Area,” “places a high priority on moving jobs and households closer to each other and to transit options,” and “leads the Bay Area in the right downward trajectory towards the 2050 [greenhouse gas] emission reduction targets.”

Pursuant to section 65080, subdivision (b)(2)(J)(ii), the Agencies submitted their adopted Plan Bay Area to the Board for its review and acceptance of their determination that the Plan, if implemented, would achieve the Board’s emissions reduction targets for the Bay Area. On April 10, 2014, the Board accepted the Agencies’ determination in Executive Order No. G-14-028. The Board’s executive order regarding Plan Bay Area referred to, and attached, the Board staff’s April 2014 final technical evaluation of the Agencies’ greenhouse gas emissions reduction quantification for their sustainable communities strategy. This evaluation states that the Agencies had “appropriately not included in [their] greenhouse gas emissions reduction figures any [greenhouse gas] emissions reductions from the [Board]-adopted technology and fuel programs, such as the Low Carbon Fuel Standard or [Pavley] program. This is because the regional targets adopted by [the Board] in 2010 do not include reductions from these statewide technology and fuel programs, but rather focus on reductions from strategies implemented at the regional and local levels.”

III.

Citizens’ Verified Petition for Writ of Mandate

In August 2013, Citizens filed a verified petition for writ of mandate in Alameda County Superior Court challenging the Agencies’ adoption of Plan Bay Area. In five causes of action, Citizens alleged the Agencies failed to comply with CEQA in their DEIR and FEIR (collectively, EIRs) by (1) not adequately identifying Plan Bay Area’s basic objectives; (2) not adequately assessing a ‘“No Project” alternative; (3) not adequately assessing a ‘“No Project” alternative by relying on “an obviously outdated baseline”; (4) not including a reasonable, feasible alternative to Plan Bay Area; and (5) not responding to Citizens’ proposed alternative plan.

According to Citizens, the Agencies imposed unnecessary land use plans on the Bay Area in order to meet the Board’s 2020 and 2035 emissions reduction targets because they improperly ignored the greenhouse gas emissions reductions expected from statewide mandates. The Agencies planned to meet the Board targets “primarily through reduction in the vehicle miles traveled (VMT) of passenger motorcars and light trucks” resulting from “high-density land-use patterns” and “construction and extension of light and heavy rail.” As a result, Plan Bay Area required “78 [percent] of new housing and 62 [percent] of new jobs, through 2040, to be located within [Priority [Development [A]reas,” defined by Citizens as “ ‘[locations within existing communities that present infill development opportunities and are easily accessible to transit, jobs, shopping and services.’ ” The new development was to be concentrated in areas that covered only 5 percent of the Bay Area region’s surface area. In Citizens’ view, the Agencies unnecessarily adopted “a draconian, high-density land-use regime.” These measures were unnecessary and were the product of the Agencies’ failure to take into account projected statewide greenhouse gas emissions reductions from other initiatives, such as Assembly Bill 32. These projected statewide reductions meant “the Bay Area can handily exceed the required greenhouse gas reductions [set by the Board pursuant to Senate Bill 375] without reliance on [the Agencies’] high-density land-use vision.”

Citizens further asserted that the Agencies’ failure to take these statewide reductions into account violated CEQA because, rather than convey this basic information in their FEIR, the Agencies assumed “ ‘hypothetical’ numbers, thereby giving the public the false impression that the [Agencies’ high-density approach (or something very close to it) is necessary to achieve the required greenhouse gas reductions. Thus, [Plan Bay Areal's CEQA analysis undercuts the law’s purposes of informing the public and decision-makers of the environmental consequences of, and alternatives to, discretionary government action.”

Citizens further claimed that Plan Bay Area’s CEQA analysis ignored three specific statewide greenhouse gas reduction mandates regarding technology and fuel composition. These were the Low Carbon Fuel Standard, and the Pavley I and Pavley II vehicle technology regulations. As a result, Citizens contended, in 2040, the last year of Plan Bay Area, California’s passenger vehicles would produce only 40 percent of the greenhouse gas emissions they produced in 2010.

Citizens also contended the Agencies’ environmental review indicated Plan Bay Area would have 39 significant environmental effects, including a substantial net increase in construction-related emissions pollution, an increase in large particulate matter pollution, the worsening of toxic air contaminant and small particulate matter pollution for some Bay Area communities, the disruption or displacement of substantial numbers of individuals and businesses, and permanent neighborhood alterations that would restrict access to or eliminate community amenities. The DEIR discussed five project alternatives, including a ‘“No Project” alternative that would not meet the Board’s greenhouse gas emissions reduction targets.

According to Citizens, it and other citizen groups provided comments on the draft Plan Bay Area and DEIR that highlighted a number of ‘“serious legal and policy shortcomings.” These included that the draft plan and the DEIR ignored Pavley’s vehicle technology standards and the Low Carbon Fuel Standard in measuring the greenhouse gas emission impacts of Plan Bay Area and the discussed alternatives, thereby creating ‘“a false need for [the Plan’s] draconian high-density development prescriptions. If [Plan Bay Area] were consistently to take the [Low Carbon Fuel Standard], Pavley I, and Pavley II into account, it would be clear to the public that the [Senate Bill 375] targets can be reached without [Plan Bay Area]’s drastic land-use changes. In fact, [the Agencies’] own models show that the difference by year 2035 between [Plan Bay Area] and the ‘no project’ alternative—taking only the [Low Carbon Fuel Standard] and Pavley I into account—will be approximately 2,000 tons per day of greenhouse gas (less than a 3 [percent] difference), well within any reasonable margin of error.” This difference was further reduced when factoring out elements of Plan Bay Area unrelated to its high-density housing and transportation policies. According to Citizens, ‘“that difference is dwarfed by the models’ own conclusion that the [Low Carbon Fuel Standard] and Pavley I will lead to 14 times more greenhouse gas emission reductions than those strictly attributable to [Plan Bay Area].” Citizens further alleged that the draft Plan Bay Area included arbitrary revenue assumptions, high-density housing mandates and mass transit elements that would actually increase greenhouse gas emissions. It also had unrealistic goals, unreliable models for predicting transit use and development decades into the future, and inaccurate assumptions regarding population and job growth.

Citizens also contended that the Agencies certified the FEIR and adopted Plan Bay Area without remedying these serious shortcomings. The FEIR included the errors previously described, and also contained the ‘“assumption that vehicle miles-per-gallon efficiency and gasoline carbon content will remain constant over the life of the Plan.” This was ‘“contrary to fact” because the Plan did “not take fully into account the greenhouse gas reductions that the region’s transportation system will achieve ‘naturally’ simply due to the implementation of the [Low Carbon Fuel Standard], Pavley I, and Pavley II,” although the Plan “selectively and opportunistically” did take these emissions improvements into account when estimating future particulate matter and other air pollutants.

According to Citizens, the Agencies incorrectly asserted that Senate Bill 375, the Board’s Scoping Plan and the Board staff’s initial review of Plan Bay Area all indicated that the Board’s Bay Area reduction targets were meant to exclude any reductions attributable to the Low Carbon Fuel Standard, Pavley I and Pavley II, since including them would be “impermissible ‘double counting.’ ” To the contrary, Citizens contended, Senate Bill 375 “expressly requires that the targets, which [Plan Bay Area] is supposed to meet, must take into account greenhouse gas reductions achieved through advances in vehicle efficiency and fuel cleanliness” pursuant to section 65080, subdivision (b)(2)(A)(iii). The Agencies’ interpretation of Senate Bill 375 in the FEIR was purportedly inconsistent with Senate Bill 375’s authorization for the Board “to update the targets based on ongoing advances in vehicle efficiency and fuel cleanliness” pursuant to 65080, subdivision (b)(2)(A)(iv).

Moreover, Citizens contended, Senate Bill 375 regulated Plan Bay Area, but not its environmental impact report. “Thus, even if [Plan Bay Area] were required to ignore emission savings from the implementation of the [Low Carbon Fuel Standard], Pavley I, and Pavley II when determining whether the targets have been met, that would not mean that the [FEIR’s] CEQA analysis should also be subject to the same fictitious assumptions.”

Further, Citizens alleged, it had recommended that the Agencies adopt an environmentally sensitive alternative to Plan Bay Area that would achieve Plan Bay Area’s basic objectives without its significant environmental effects. Citizens’ alternative reasonably relied on “the anticipated substantial greenhouse gas reductions that will occur over the planning horizon owing to the [Low Carbon Fuel Standard], Pavley I, and Pavley II,” called for “increasing and improving transit lines further to reduce greenhouse gases,” and could “easily achieve the housing goals for the region, because it is not limited by [Plan Bay Area’s] draconian high-density housing mandate.”

Nonetheless, Citizens alleged, the FEIR failed to consider its alternative, stating instead that the Agencies were “not required to consider every possible alternative, and that existing alternatives adequately incorporate[d] the main parts of the Citizens’ alternative.” Yet the FEIR did not explain how the alternatives discussed in it were adequate, given that they all ignored the reductions from the Low Carbon Fuel Standard, Pavley I and Pavley II. In other words, the FEIR’s disregard of the Citizens alternative was “based entirely on its faulty interpretation of [Senate Bill 375] as requiring that the Plan ignore greenhouse-gas-reduction reality when determining whether [Plan Bay Area] will meet the regional targets.” Citizens also challenged the Agencies’ issuance of a Statement of Overriding Considerations to support Plan Bay Area.

Citizens sought a peremptory writ of mandate directing the Agencies to vacate their certification of the FEIR, adoption of the Statement of Overriding Considerations and approval of Plan Bay Area, and to produce a new FEIR consistent with CEQA.

IY.

The Agencies' Answer to Citizens' Petition

The Agencies answered Citizens’ petition. They denied there was anything improper about their FEIR, Statement of Overriding Considerations, or Plan Bay Area.

The Agencies acknowledged Plan Bay Area relied on “a strategy of focusing growth around the region’s existing and planned public transit system,” primarily through the Priority Development Area framework, and that the Priority Development Areas were “expected to accommodate 78 percent of new housing (approximately 509,000 units) and 62 percent of new jobs (approximately 690,000).” The Agencies stated that, “[d]ue to this focused growth pattern and the associated investments into the public transit system, [Plan Bay Area] [was] forecasted to result in 93 percent more transit boardings and 6 percent fewer vehicle miles traveled per capita by the year 2040,” including significant increases in daily transit seat miles, most notably in heavy rail and commuter rail transit. “These changes in passenger travel patterns, along with the land use pattern and other transportation and climate program investments, [were] expected to reduce per-capita light-duty vehicle greenhouse gas emissions by 10 percent between 2005 and 2020 and 16 percent between 2005 and 2035,” exceeding the Board’s Senate Bill 375 targets of 7 percent by 2020 and 15 percent by 2035.

The Agencies acknowledged their EIR (environmental impact report) analysis had concluded Plan Bay Area would result in 39 significant and unavoidable environmental effects. However, the Agencies contended, 23 of these effects could be mitigated to less than significant at the project level.

V.

The Trial Court’s Statement of Decision

Citizens moved for judgment on its petition, and the parties submitted briefs and a voluminous administrative record. The trial court held a hearing on Citizens’ motion, issued a proposed statement of decision and received the parties’ comments.

On August 8, 2014, the court issued a thorough and well-thought-out 33-page final statement of decision denying Citizens’ petition. The court noted that the parties submitted briefs consistent with their pleadings and that Citizens’ contentions and arguments focused on its basic premise that Plan Bay Area should have striven to achieve the Board’s 2020 and 2035 emissions reduction targets by considering the anticipated reductions from Pavley and the Low Carbon Fuel Standard. The court first reviewed the statutes, regulations and plans that led up to Plan Bay Area and then reviewed the Agencies’ EIRs.

A. The Court’s Discussion of the DEIR

The court found the DEIR contained statements that identified goals for Plan Bay Area. These included that the Plan “ ‘aims to achieve focused growth by building off of locally-identified Priority Development Areas and by emphasizing strategic investments in the region’s transportation network including strong emphasis on operating and maintaining the existing system,’ ” and that the Plan had seven goals: “ ‘(1) Climate Protection (2) Adequate Housing (3) Healthy and Safe Communities (4) Open Space and Agricultural Preservation (5) Equitable Access (6) Economic Vitality [and] (7) Transportation System Effectiveness.’ ” Further, the DEIR identified the “ ‘climate change’ ” goal as the reduction of “ ‘per-capita C02 emissions from cars and light-duty trucks by 15 [percent] as required by [Senate Bill] 375.’ ”

The court further found that the DEIR did not include anticipated greenhouse gas emissions reductions from Pavley or the Low Carbon Fuel Standard in its analysis of Criterion 1 environmental effects (failure to reduce per capita passenger vehicle and light duty truck C02 emissions by at least the Board’s 2020 and 2035 targets), but included them in its evaluation of Criterion 2 (whether there was a net increase in direct and indirect greenhouse gas emissions in 2040 when compared to existing conditions) and Criterion 3 (the attainment of goals set forth in Exec. Order No. S-3-05 and Exec. Order No. B-16-2012 by 2050) effects. The trial court concluded this difference was because the DEIR is “not bounded by the statutory requirements of SB 375 in its evaluation of the [Criterion] 2 issue” and, therefore, evaluated transportation emissions for “ ‘all vehicle classes and the emissions reduction benefits from Pavley and the [Low Carbon Fuel Standard].’ ”

The trial court also found that anticipated Pavley and Low Carbon Fuel Standard reductions were considered in the DEIR’s evaluation of the Criterion 3 issue. This issue implicated whether the proposed Plan was consistent with Executive Order No. S-3-05, which calls for the reduction of greenhouse emissions to 20 percent of the 1990 level by 2050. The Criterion 3 analysis included two charts, one which did not consider and one which did consider anticipated Pavley and the Low Carbon Fuel Standard reductions.

The court emphasized that the Board staff’s June 2013 draft technical evaluation of the Agencies’ proposed plan stated that the Agencies had “ ‘appropriately not included [greenhouse gas] emissions reductions from the technology and fuel programs adopted by the [Board] such as the Low Carbon Fuel Standard and [Pavley]. This [was] because the targets adopted by [the Board] in 2010 [did] not include reductions from these statewide technology and fuel programs but rather focus[ed] on reductions from strategies implemented at the regional and local levels.’ ”

The trial court further found that the DEIR evaluated five “potentially feasible” alternative sustainable communities strategies, and that the DEIR concluded these alternatives had only “minor” overall variations in environmental impact.

The trial court further discussed that, as part of the public comments about the DEIR, Citizens “asserted that the . . . analysis failed to account for, and hid, the fact that the Pavley mileage regulations will increase vehicle [miles per gallon] and will decrease emissions by approximately 37 [percent] and instead conducted a flawed analysis that assumed constant fleet [miles per gallon] through 2035.” Citizens proposed its own alternative plan, the “Bay Area Citizens Transportation and Housing Alternative.”

The court found the FEIR responded to Citizens when it “explained why the [DEIR] focused on emissions reductions from the land use and transportation planning sector while not factoring in emissions reductions from the Pavley mileage regulations and the [the Low Carbon Fuel Standard].” The FEIR stated that “ ‘ABAG focused solely on land use and transportation planning [greenhouse gas] reduction measures and used a 2005 baseline for their analysis of [greenhouse gas] emissions reductions under the Plan because that is what SB 375 and [the Board] require. Pavley and the [Low Carbon Fuel Standard] are separate components of the State’s [greenhouse gas] emissions reduction efforts. [The Agencies] would be impermissibly double-counting the reductions from Pavley and the [Low Carbon Fuel Standard] if they were to take credit for those emissions reductions in this EIR. [The Board] selected the year 2005 as a baseline (see p. 6 in the Recommendations of the Regional Targets Advisory Committee) in September 2009. The purpose of developing the [sustainable communities strategy] as a component of the [regional transportation plan] is to provide a tool for regional governing bodies, such as [the Agencies], to meet [the Board’s greenhouse gas] reduction targets specific to the land use and transportation planning sector.’ ”

The trial court further found that the FEIR had sufficiently responded to Citizens’ comments. The FEIR stated that “ ‘[consistent with [Senate Bill] 375,’ ” the Board assigned the Agencies targets that required emissions reductions “ ‘beyond those achieved by “new vehicle technology and by the increased use of low carbon fuel” ([Sen. Bill] 375 Section 1(c)).[] ... As such, for the purposes of [Senate Bill] 375, [the Agencies] must estimate carbon dioxide emissions assuming [a] hypothetical future in which new vehicle technologies and the increased use of low carbon fuel are not present.’ ” Further, “ ‘[w]hen assessing the environmental impact of the proposed action, [the Agencies] assume a policy future in which new vehicle technology and the increased use of low carbon fuel do exist. . . . [¶] For each scenario, therefore, [the Agencies] have two estimates of effective miles per gallon [MPG]. One is the expected future year value, expected MPG, and is used as part of the emission estimation process that is the basis for assessing the environmental impact of the proposed action. The second is the hypothetical value, SB 375, which is used as part of carbon dioxide estimation process that is the basis for [the Agencies’] [Senate Bill] 375 [greenhouse gas] target. The only purpose of this hypothetical second value is for computing [the Agencies’] [Senate Bill] 375 [greenhouse gas] target. [¶] . . . [¶] [The Agencies] cannot rely on state-mandated changes in vehicle technology and increased use of low carbon fuel to meet the region’s [Senate Bill] 375 target.’ ” The court continued, their “use of these two separate MPG estimates for two separate purposes is not a secret.” Elsewhere in response to Citizens’ comments, the FEIR referred to the conclusion in the DEIR that, in meeting the Senate Bill 375 greenhouse gas emissions reduction targets, it was prohibited from including anticipated Pavley and the Low Carbon Fuel Standard reductions in its calculations.

B. The Court’s Rulings on Citizens’ Claims

The court then stated its rulings on the claims Citizens had brought, which the court divided into five categories.

First, the court rejected Citizens’ basic premise that the Agencies should have considered emissions reductions from Pavley and the Low Carbon Fuel Standard in determining how Plan Bay Area would meet the Board’s 2020 and 2035 greenhouse gas emissions reduction targets. The court concluded, based on its review of statutory text, the purpose of a regional transportation plan, the Legislature’s declarations and the Board’s interpretations, that Senate Bill 375 requires the Agencies to develop a regional transportation plan independent of Pavley and the Low Carbon Fuel Standard.

Second, the court rejected Citizens’ contention that the Agencies failed to disclose and describe Senate Bill 375’s proper legal objective. The court found substantial evidence to the contrary, in that the DEIR identified seven goals of the proposed Plan Bay Area and “was clear that in meeting the goal of reducing per-capita C02 emissions from cars and light-duty trucks by 15 [percent,] [Plan Bay Area] would be limiting itself to land use and transportation issues.” Further, numerous public comments indicated the public’s understanding that the plan sought to achieve the Board’s targets independent of Pavley and the Low Carbon Fuel Standard, and there was substantial evidence that the Agencies responded adequately to the public comments, including those by Citizens.

Third, the trial court rejected Citizens’ claim that the Agencies did not comply with CEQA because they used the Senate Bill 375 framework to analyze the proposed Plan Bay Area’s impact on greenhouse gas emissions, rather than some other framework. The court found the Agencies had acted within their discretion by analyzing the Plan’s impact under three different criteria: the Senate Bill 375 standard for meeting reductions targets with a 2005 base year for 2020 (7 percent) and 2035 (15 percent) (Criterion 1); the Agencies’ goal of achieving reductions by 2040 using a 2010 baseline (Criterion 2); and the executive order goals of achieving reductions by 2050 equivalent to 80 percent of emissions in 1990 (Criterion 3).

Fourth, the trial court rejected Citizens’ claim that the Agencies did not properly consider the “No Project” alternative. As we have discussed, the court rejected Citizens’ contention that the Agencies misinterpreted Senate Bill 375 to exclude reductions from Pavley and the Low Carbon Fuel Standard. The court also concluded that, contrary to Citizens’ argument, the Agencies properly used 2005 as a base year in considering the No Project alternative because Senate Bill 375 required the Agencies to do so. Finally, Citizens contended that the Agencies neglected to assess the “real world” consequences of the No Project alternative by projecting that Bay Area emissions would continue to rise despite evidence that nationwide emission rates for the transportations sector have been leveling off; the trial court found substantial evidence supported the Agencies’ projection.

Fifth, the trial court rejected Citizens’ assertion that the Agencies did not properly consider and assess Citizens’ proposed alternative plan. The court concluded there were three reasons why the Agencies had met their obligation to consider a reasonable range of potentially feasible alternative plans. First, in their environmental review, they considered several alternative plans and, the court found, there was substantial evidence that the Agencies did not need to conduct a separate evaluation of Citizens’ alternative plan. Second, the Agencies were not required to consider Citizens’ alternative plan because it was infeasible, given that it improperly included emissions reductions from the Pavley regulations and the Low Carbon Fuel Standard. Third, the Agencies considered several aspects of Citizens’ alternative plan in the course of their evaluations of other alternatives, and adequately responded to Citizens, pointing out that they had considered a reasonable range of alternatives and that many elements of Citizens’ alternative plan were included in the alternatives assessed.

VI.

Filing of the Judgment and Notice of Appeal

On August 27, 2014, the trial court filed a judgment that incorporated its final statement of decision and denied Citizens’ petition in its entirety.

Citizens filed a timely notice of appeal. During the pendency of this appeal, the Agencies made an unopposed request for judicial notice of certain documents, which we granted. Further, the Attorney General filed an amicus curiae brief in support of the Agencies, which we have also considered.

DISCUSSION

As in its petition for writ of mandate in the trial court, on appeal Citizens contends that the Agencies did not comply with CEQA in several ways, all because the Agencies improperly relied “throughout ... on the assertion that [Senate Bill 375] and the [Board] targets forbid any consideration of the Statewide Mandates in assessing whether the targets will be met.”

The Agencies contend Senate Bill 375 and the Board require them to strive to meet the Board’s emissions reduction targets by developing regional land use and transportation strategies that were independent of the statewide mandates. The Attorney General contends the Agencies complied with CEQA because of their EIRs’ extensive disclosures and analyses, regardless of Senate Bill 375’s and the Board’s requirements.

We agree with both the Agencies and the Attorney General, as we will now discuss.

I.

Legal Standards Governing CEQA Review

“ ‘[T]he foremost principle under CEQA is that the Legislature intended the act “to be interpreted in such manner as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language.” ’ ” (Muzzy Ranch Co. v. Solano County Airport Land Use Com. (2007) 41 Cal.4th 372, 381 [60 Cal.Rptr.3d 247, 160 P.3d 116] (Muzzy Ranch Co.).) “The fundamental goal of an EIR is to inform decision makers and the public of any significant adverse effects a project is likely to have on the physical environment.” (Neighbors for Smart Rail v. Exposition Metro Line Construction Authority (2013) 57 Cal.4th 439, 447 [160 Cal.Rptr.3d 1, 304 P.3d 499].) It serves as “ ‘an “environmental ‘alarm bell’ whose purpose it is to alert the public and its responsible officials to environmental changes before they have reached ecological points of no return.” [Citations.] The EIR is also intended “to demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action.” ’ ” (Californians for Alternatives to Toxics v. Department of Food & Agriculture (2005) 136 Cal.App.4th 1, 11-12 [38 Cal.Rptr.3d 638] (Californians for Alternatives to Toxics), quoting Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 392 [253 Cal.Rptr. 426, 764 P.2d 278].)

“As a general matter the EIR must present facts and analysis, not simply the bare conclusions or opinions of the agency. [Citation.] The discussion of impacts is acceptable if it provides sufficient information and analysis to allow the public to discern the basis for the agency’s impact findings. [Citation.] Thus the EIR should set forth specific data, as needed to meaningfully assess whether the proposed activities would result in significant impacts.” (Californians for Alternatives to Toxics, supra, 136 Cal.App.4th at p. 13.)

In a CEQA case, “our review of the administrative record for error is the same as the trial court’s; we review the agency’s action, not the trial court’s decision.” (Muzzy Ranch Co., supra, 41 Cal.4th at p. 381.) Our review extends only to “whether there was a prejudicial abuse of discretion. Abuse of discretion is established if the agency has not proceeded in a manner required by law or if the determination or decision is not supported by substantial evidence.” (Pub. Resources Code, § 21168.5; see Save Tara v. City of West Hollywood (2008) 45 Cal.4th 116, 131 [84 Cal.Rptr.3d 614, 194 P.3d 344].)

“[A]n agency’s failure to comply with the procedural requirements of CEQA is prejudicial when the violation thwarts the act’s goals by precluding informed decisionmaking and public participation.” (San Lorenzo Valley Community Advocates for Responsible Education v. San Lorenzo Valley Unified School Dist. (2006) 139 Cal.App.4th 1356, 1375 [44 Cal.Rptr.3d 128].) Thus, an EIR “will be found legally inadequate—and subject to independent review for procedural error—where it omits information that is both required by CEQA and necessary to informed discussion.” (California Native Plant Society v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 986 [99 Cal.Rptr.3d 572].)

In contrast, when reviewing a challenge to an agency’s factual findings and determinations, we apply the substantial evidence standard. (San Joaquin Raptor Rescue Center v. County of Merced (2007) 149 Cal.App.4th 645, 654 [57 Cal.Rptr.3d 663].) “ ‘Substantial evidence’ ” is “enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached,” based on a review of the whole record before the agency. (Cal. Code Regs., tit. 14, § 15384, subd. (a).) “Argument, speculation, unsubstantiated opinion or narrative, evidence which is clearly erroneous or inaccurate, or evidence of social or economic impacts which do not contribute to or are not caused by physical impacts on the environment does not constitute substantial evidence.” (Ibid.) We consider “all relevant evidence, including that which detracts from the administrative decision.” (Ross v. California Coastal Com. (2011) 199 Cal.App.4th 900, 921 [133 Cal.Rptr.3d 107].)

Further, ‘“[t]he agency’s findings and actions are presumed to be supported by substantial evidence. [Citations.] A person challenging an administrative determination bears the burden of showing the agency’s findings are not supported by substantial evidence.” (Ross v. California Coastal Com., supra, 199 Cal.App.4th at p. 921.)

II.

The Meaning of Senate Bill 375

Citizens first argues that, ‘“contrary to the Agencies’ evident wish,” Senate Bill 375 does not require that the Agencies meet the Board’s emissions reduction targets without considering reductions expected from statewide mandates such as Pavley and the Low Carbon Fuel Standard. According to Citizens, ‘“the Agencies’ approach is itself legally suspect, particularly given [Senate Bill 375 ’s] mandate that the regional targets must take account of’ emissions reductions expected from the statewide mandates. And regardless, Citizens contends its interpretation, even if not compelled by Senate Bill 375, is “nevertheless a reasonable interpretation of the statute. [Citation.] Considering regional transportation planning and the Statewide Mandates together as part of a cumulative target analysis is a sensible approach to ensure that the two factors (which necessarily affect and interact with the other) co