CORRESPONDENCE - 75D - Laserfiche WebLink

Home Browse Search

MainPlace Transformation Project City Council Agenda Item 75D June 4, 2019 Page 9 Freeway, Main Street) and the high levels of PM2.5 already present in the ambient air. Offermann Comments, pp. 10-11. No analysis has been conducted of the significant cumulative health impacts that will result to residents and employees living and working at the Project. The Addendum fails to disclose, analyze, or mitigate these new significant impacts. Because Mr. Offermann's expert review is substantial evidence of a fair argument of a significant environmental impact to future users of the project, an EIR must be prepared to disclose and mitigate those impacts. B. There is Substantial Evidence Supporting a Fair Argument that the Project Will Result in a Significant Climate Change Impact. The Addendum relies on an efficiency -based greenhouse gas emission analysis to determine the significance of the Project's climate change impact. The Addendum concludes that the Project would have a GHG efficiency of 2.84 MT CO2e/year/service population. Addendum, p. 119. Since this falls below the 3.0 MT CO2e/year/service population South Coast Air Quality Management District ("SCAQMD") threshold of significance, the Addendum concludes that the Project will not have a significant GHG impact. Id. As explained in the expert comments of environmental consulting firm SWAPE, this conclusion is incorrect because the Addendum relies on a flawed methodology. SWAPE Comment, p. 7. The Addendum calculates the Project's "net emissions" by subtracting the GHG emissions associated with the existing land uses from the GHG emissions associated with the currently proposed Project. Based on this analysis, the Addendum concludes that the Project would not result in a new significant or more severe GHG impact than was analyzed in the 1983 EIR. Addendum, p. 119. The Addendum errs by making its determination of the significance of the Project's climate change impact based on the Addendum's "net emissions" calculations. The question is not whether the additional impact the Project will have is significant. The question is whether the Project's total emissions will result in a new or more significant impact, where there was not previously one. Without an analysis of the GHG impact of the Project as a whole, there is no substantial evidence to support the Addendum's conclusion that the Project will not have a new or substantially greater significant climate change impact as a result of the significant changes the Project proposes. While the Addendum does not include this analysis, SWAPE conducted the analysis in order to accurately evaluate the Project's GHG impacts. SWAPE Comments, p. 9. Relying on the Project's total emissions, rather than net emissions, SWAPE found that the Project's emissions will actually be 7.35 MT CO2e/year/service population, which is more than double the 3.0 MT CO2e/year threshold of significance. Id. SWAPE's expert opinion constitutes substantial evidence that the Project will have a significant new or more significant impact that was not previously analyzed in the 1983 EIR. An EIR is needed to fully disclose, analyze, and mitigate this significant impact.