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11 Greenhouse Gas Failure to Adequately Evaluate Greenhouse Gas Impacts The Addendum concludes that the proposed Project would have a less than significant GHG impact as a result of determining that emissions would be less than that indicated in the 2010 FEIR, as well as a qualitative analysis evaluating the Project’s consistency with the California Building Code, Santa Ana Climate Action Plan (CAP), and CARB’s 2017 Scoping Plan. Specifically, the Addendum states, “[T]he proposed project would generate approximately 2,231 MT CO2e per year. The proposed project’s emissions would be less than the emissions identified by the 2010 FEIR. In addition, there have been substantial changes in the California Building Code since the 2010 FEIR was adopted to increase efficiency and reduce GHG emissions, which contribute to achieving GHG reductions identified by AB 32. The project would comply with the California Building Code, which would reduce GHG emissions and increase efficiency, beyond what was assumed in the 2010 FEIR. Therefore, the project would not result in any new or substantially more severe GHG emissions impacts than what was analyzed in the 2010 FEIR and project GHG emissions would not be significant” (p. 3.5-2). The Addendum goes on to state, “[T]he proposed project would be consistent with the Santa Ana CAP. The proposed project would not result in any new or substantially more severe GHG emissions impacts beyond those analyzed in the 2010 FEIR and cumulative GHG emissions would not be significant” (p. 3.5-3). Finally, the Addendum states, “On December 14, 2017, CARB adopted the 2017 Scoping Plan, which provides a framework for achieving the 2030 target. Therefore, the proposed project should be consistent with the most recent Scoping Plan…The proposed project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. Therefore, the proposed project would not result in any new or substantially more severe GHG emissions impacts than what was analyzed in the 2010 FEIR and project impacts would not be significant” (p. 3.5-3 – 3.5-4). This justification and subsequent less-than-significant impact finding are incorrect and unsubstantiated for several reasons: (1) The Addendum fails to demonstrate consistency with the FEIR; (2) The Santa Ana County CAP cannot be relied upon to determine Project significance; (3) The 2017 CARB Scoping Plan cannot be relied upon to determine Project significance; (4) Incorrect and unsubstantiated analysis demonstrates significant GHG impact; and (5) Updated analysis indicates significant impact.