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23 As you can see in the excerpt above, when we compare the per service population emissions estimated in the Addendum to the relevant SCAQMD threshold, the Project’s 2022 service population efficiency value of 3.42 MT CO2e/SP/year exceeds the 2035 service population efficiency threshold of 3.0 MT CO2e/SP/year. Thus, we find a significant GHG impact not previously identified in the Addendum. According to CEQA Guidelines § 15064.4(b), if there is substantial evidence that the possible effects of a particular project are still cumulatively considerable notwithstanding compliance with the adopted regulations or requirements, a full CEQA analysis must be prepared for the project. The Addendum may not ignore this analysis and application of routinely used GHG thresholds by claiming discretion in deciding which thresholds it wishes to employ. As one court explained when setting aside an EIR where commenters questioned the city’s use of a particular threshold, the discretion granted to lead agencies are not “unbounded” and (emphasis added): “[T]he fact that a particular environmental effect meets a particular threshold cannot be used as an automatic determinant that the effect is or is not significant … a threshold of significance cannot be applied in a way that would foreclose the consideration of other substantial evidence tending to show the environmental effect to which the threshold relates might be significant.” East Sacramento Partnership for a Livable City v. City of Sacramento (2016) 5 Cal.App.5th 281, 300, 303-304 (internal citations omitted). Thus, the results of the above analysis provide substantial evidence that the proposed Project’s GHG emissions are still cumulatively considerable notwithstanding its purported compliance with the FEIR, Santa Ana CAP, and 2017 CARB Scoping Plan (as challenged herein). Therefore, an updated CEQA analysis must be prepared for the Project, and mitigation should be implemented where necessary, per CEQA guidelines. (5) Updated Analysis Indicates Significant Impact In an effort to adequately assess the Project’s GHG impact, we prepared a simple analysis using the emission estimates provided in the SWAPE CalEEMod output files and compared them to the SCAQMD’s 2035 service population efficiency threshold. According to the CalEEMod output files, the amortized construction of the Project would result in approximately 35.5 MT CO2e per year27 and operation of the Project would result in a net emission increase of approximately 2,529.8 MT CO2e.28 According to CAPCOA’s CEQA & Climate Change report, service population is defined as “the sum of the number of residents and the number of jobs supported by the project.”29 According to the Addendum, the Project would result in 629 new residents (Appendix C, pp. 135, 163, 188). The Addendum failed to provide the estimated number of employees supported by the Project, so we estimated a value of 24 new employees, based on the square footage of the proposed retail land use and USGBC’s Building Area 27 Amortized Construction = (393.31 + 653.88 + 16.82) / 30 = 35.5 MT CO2e 28 Net Operational = Area + Energy + Mobile + Waste + Water = (56.95 + 713.72 + 1,661.83 + 57.94 + 39.32) = 2,529.76 MT CO2e 29 CAPCOA (Jan. 2008) CEQA & Climate Change, p. 71-72, http://www.capcoa.org/wp- content/uploads/2012/03/CAPCOA-White-Paper.pdf.