In Center for Biological Diversity v. Dept. of Fish and Wildlife,1 the California Supreme Court upheld the “Business as Usual” (BAU) approach for analyzing greenhouse gas (GHG) emissions under the California Environmental Quality Act (CEQA), but then set a precariously high bar for application of BAU. The Court generally endorsed reliance on consistency with the state’s goal of reducing GHG emissions by 29 percent compared to BAU, pursuant to Assembly Bill (AB) 32, as a standard for identifying significant GHG impacts pursuant to CEQA. In this case, however, the record failed to show that the individual project’s 31 percent reduction in GHG emissions was consistent with the statewide goal of 29 percent reduction. The project might need to do still more than achieve a 29 percent or 31 percent GHG reduction from BAU, the Court reasoned, because other projects and existing development may do less. While this consistency showing is logical in theory, in practice it will not be easy to make.