In 2007, then-Attorney General Jerry Brown established a new paradigm for planning in California. With his settlement in a lawsuit against San Bernardino County, he clearly signaled that cities, counties, and county subregions would have to account for, and attempt to mitigate, greenhouse gas emissions in their general plans under the California Environmental Quality Act and AB 32. In fact, Brown went so far as to vow to sue any city that failed to account for its greenhouse gas emissions.
