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emissions of 22,698 MT CO2e/year (2019 Addendum, p. 119—120)," Then, the Applicant calculates the GHG emissions efficiency by dividing the Project's "net emissions" by the anticipated service population of 8,001 people, which results in a GHG emissions efficiency of approximately 2.84 MT CO2e/year/service population (see excerpt below) (2019 Addendum, p. 119—120).14 Table AQ-6: Net Service Population GHG Emissions Emissions Source (Net New Building Area) Net Emissions MTCO2e/year Net Service Population MTCO2e/yea rl Service Population Originally Approved (1983) Plan 38,787 5,181 7,49 Current Entitlement 22,325 4,462 5.00 Proposed Project 22,698 8,001 2.84 Proposed Project Minus Originally Approved (1983) Plan 15,089 2,829 4.55 Proposed Project Minus Current Entitlement 373 3,539 -2.16 Source: Greenhouse Gas Emissions Assessment, 2019 As a result of the calculated GHG efficiency above, the 2019 Addendum concludes that "the impacts related to GHG emissions would be less than significant" (2019 Addendum, p. 119). We find this significance determination to be unsubstantiated, as the Project Applicant incorrectly utilizes "net emissions" to calculate the Project's GHG emissions efficiency. The Applicant's reliance on the proposed Project's net GHG emissions, rather than the Project's total GHG emissions, is incorrect and inconsistent with guidance set forth by the Office of Planning and Research (OPR). In the Final Statement of Reasons for Regulatory Action," OPR concluded that lead agencies cannot simply consider whether a project increases or decreases GHG emissions at the project site, but must consider the effect that the project will have on the larger environment. Accordingly, if a lead agency wants to use a net emissions approach by subtracting existing on -site emissions from the proposed project emissions, it must support that decision with substantial evidence that those existing emissions sources will be extinguished and not simply displaced." It is clear, however, that the existing land uses will be retained on the site and ultimately operational as part of the total Project. The Greenhouse Gas Emissions Assessment states that the "total building area for MainPlace Mall is currently 1,130,000 sf of commercial / retail uses" and goes on to state that the 13 Net Emissions = Proposed Project Emissions — Existing Emissions = 58,835 MT CO2e/year — 36,137 MT CO2e/year = 22,698 MT CO2e/year 14 2019 Addendum Per Service Population Efficiency = Net Emissions / Service Population = (22,698 MT CO2e/year) / 8,001 people = 2.84 MT CO2e/year/SP 16 "Final Statement of Reasons for Regulatory Action." California Natural Resources Agency, December 2009, available at: htto://resources.ca.gov/cega/dots/Final Statement of Reasons.odf, p.83-84 16 See CEQA Guidelines, § 15064.4, subd. (a) ("The determination of the significance of greenhouse gas emissions calls for a careful judgment by the lead agency consistent with the provisions in section 15064. A lead agency should make a good -faith effort, based on available information, to describe, calculate or estimate the amount of greenhouse gas emissions resulting from a project.")