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Given the construction schedule, the Project is not set to become operational until the end of 2022 (Appendix C, pp. 135, 163, 188). However, the City of Santa Ana's CAP is only applicable to Project's that will be fully operational by 2020, as the CAP should be updated to meet the 2035 goals included in the CAP. Thus, we require that an updated CEQA analysis be prepared to include an adequate evaluation and mitigation of the proposed Project's GHG emissions to ensure that impacts are reduced to a less than significant level. (3) The 2017 CARB Scoping Plan Cannot be Relied Upon to Determine Project Significance; The Addendum determines that the Project's GHG impact would be less than significant as a result of consistency with CARB's Scoping Plan. However, this is incorrect. CEQA Guidelines § 15064.4(b)(3) allows a lead agency to consider "[t]he extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions (see, e.g., section 15183.5(b))." (Emph. added). When adopting this language, the California Natural Resources Agency ("Resources Agency') explained in its 2018 Final Statement of Reasons for Regulatory Action ("2018 Statement of Reason")23 that it explicitly added referenced to section 15183.5(b) because it was "needed to clarify that lead agencies may rely on plans prepared pursuant to section 15183.5 in evaluating a project's [GHG] emissions ... [and] consistent with the Agency's Final Statement of Reasons for the addition of section 15064.4, which states that 'proposed section 15064.4 is intended to be read in conjunction with ... proposed section 15183.5. Those sections each indicate that local and regional plans may be developed to reduce GHG emissions."' 2018 Final Statement of Reason, p. 19 (emph. added); see also 2009 Final Statement of Reasons for Regulatory Action, p. 27.24 When read in conjunction, CEQA Guidelines §§ 15064.4(b)(3) and 15183.5(b)(1) make clear qualified GHG reduction plans (also commonly referred to as a Climate Action Plan ["CAP"]) should include the following features: (1) Inventory: Quantify GHG emissions, both existing and projected over a specified time period, resulting from activities (e.g., projects) within a defined geographic area (e.g., lead agency jurisdiction); (2) Establish GHG Reduction Goal: Establish a level, based on substantial evidence, below which the contribution to GHG emissions from activities covered by the plan would not be cumulatively considerable; (3) Analyze Project Types: Identify and analyze the GHG emissions resulting from specific actions or categories of actions anticipated within the geographic area; 23 Resources Agency (Nov. 2018) Final Statement of Reasons For Regulatory Action: Amendments To The State CEQA Guidelines, http://resources.ca.gov/cega/docs/2018 CEQA Final Statement of%20Reasons 111218.pdf. 24 Resources Agency (Dec. 2009) Final Statement of Reasons for Regulatory Action, p. 27 ("Those sections each indicate that local and regional plans may be developed to reduce GHG emissions. If such plans reduce community -wide emissions to a level that is less than significant, a later project that complies with the requirements in such a plan may be found to have a less than significant impact."), http://resources.ca.gov/cega/ docs/Final Statement of Reasons.pdf. 20