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21 (4) Craft Performance Based Mitigation Measures: Specify measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve the specified emissions level; (5) Monitoring: Establish a mechanism to monitor the CAP progress toward achieving said level and to require amendment if the plan is not achieving specified levels; The above-listed CAP features provide the necessary substantial evidence demonstrating a project’s incremental contribution is not cumulative considerable, as required under CEQA Guidelines § 15064.4(b)(3).25 Here, however, the Addendum fails to demonstrate that the plans and policies include the above-listed requirements to be considered a qualified CAP for the City. As such, the Addendum leaves an analytical gap showing that compliance with said plans can be used for a project-level significance determination. Thus, the Addendum’s GHG analysis should not be relied upon to determine Project significance. (4) Incorrect and Unsubstantiated Analysis Demonstrates Significant GHG Impact In addition to the Addendum’s failure to demonstrate compliance with the FEIR, the Addendum fails to adequately compare the Project’s annual GHG emissions to the applicable SCAQMD threshold. First, the FEIR states “[w]ith programmatic mitigation incorporated at the individual component level, the components themselves may be less than significant on a site-by-site basis, but will be required to do individual air quality impact analyses to determine their independent significance levels” (p. 4.13-18). However, while the Addendum quantifies the Project’s GHG emissions, it fails to determine the Project’s significance levels based on relevant SCAQMD thresholds. Review of the Addendum demonstrates that the Project would result in a net increase of 2,231 metric tons of CO2 equivalents per year (MT CO2e/year) (see excerpt below) (p. 3.5-2). 25 See Mission Bay Alliance v. Office of Community Investment & Infrastructure (2016) 6 Cal.App.5th 160, 200-201 (Upheld qualitative GHG analysis when based on city’s adopted its greenhouse gas strategy that contained “multiple elements” of CEQA Guidelines § 15183.5(b), “quantification of [city’s] baseline levels of [GHG] emissions and planned reductions[,]” approved by the regional air district, and “[a]t the heart” of the city’s greenhouse gas strategy was “specific regulations” and measures to be implemented on a “project-by-project basis … designed to achieve the specified citywide emission level.”).