Michael Zischke was quoted in an August 8, 2011 article about the application of court rulings to reduce greenhouse gases in development. The article focused on a July 2011 case in Chula Vista involving a Target store. The 4th District Court of Appeals heard the case in which local environmental groups challenged the project’s CEQA analysis, arguing that the city did not properly calculate the project’s greenhouse gas emissions. The ruling gives more support to the decision by several public agencies to rely on California's global warming laws in settling thresholds, but it has not settled the issue.
“I wouldn’t say anything in climate change is free from controversy," Zischke said. "I think that parties will still argue that stronger thresholds should ally and litigation will continue.