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4th and Mortimer CEQA Addendum <br />October 12, 2020 <br />Page 13 of 15 <br />Quality Management District (SCAQMD) CEQA significance threshold of 10 per million. <br />SWAPE also calculates that the Project will have significant greenhouse gas impacts. <br />(SWAPE 23). SWAPE concludes that the Addendum fails to impose all feasible <br />mitigation measures to reduce the Project's air quality impacts. <br />Exceedance of Air District thresholds establishes a significant impact under CEQA. <br />Indeed, in many instances, such air quality thresholds are the only criteria reviewed and <br />treated as dispositive in evaluating the significance of a project's air quality impacts. See, <br />e.g. Schenck v. County of Sonoma (2011) 198 Cal.App.4th 949, 960 (County applies <br />BAAQMD's "published CEQA quantitative criteria" and "threshold level of cumulative <br />significance"). See also Communities fora Better Environment v. California Resources <br />Agency (2002) 103 Cal.App.4th 98, 110-111 ("A 'threshold of significance' for a given <br />environmental effect is simply that level at which the lead agency finds the effects of the <br />project to be significant"). The California Supreme Court recently made clear the <br />substantial importance that a BAAQMD significance threshold plays in providing <br />substantial evidence of a significant adverse impact. Communities for a Better <br />Environment v. South Coast Air Quality Management Dist. (2010) 48 CalAth 310, 327 <br />("As the [South Coast Air Quality Management] District's established significance <br />threshold for NOx is 55 pounds per day, these estimates [of NOx emissions of 201 to 456 <br />pounds per day] constitute substantial evidence supporting a fair argument for a <br />significant adverse impact"). <br />An EIR is required to analyze and mitigate the Project's significant air quality and <br />greenhouse gas impacts. <br />E. EVEN IF THE 2010 EIR WERE STILL RELEVANT TO THE PROJECT, A <br />SUPPLEMENTAL OR SUBSEQUENT EIR IS NECESSARY BECAUSE <br />SUBSTANTIAL CHANGES WILL RESULT IN NEW AND MORE SIGNIFICANT <br />ENVIRONMENTAL IMPACTS. <br />Even assuming that the 2010 EIR had some relevance to evaluating the <br />environmental impacts of this Project, numerous substantial changes in the development <br />plans have occurred such as the increase in massing and density, new information of <br />substantial importance has arisen, and substantial changes in circumstances have taken <br />place that require a wholesale revision of the dated 2010 EIR. <br />When changes to a project's circumstances or new substantial information comes <br />to light subsequent to the certification of an EIR for a project, the agency must prepare a <br />subsequent or supplemental EIR if the changes are "[s]ubstantial" and require "major <br />revisions" of the previous EIR. Friends of Coll. of San Mateo Gardens v. San Mateo Cty. <br />Cmty. Coll. Dist. (2016) 1 Cal.5th 937, 943. "[W]hen there is a change in plans, <br />circumstances, or available information after a project has received initial approval, the <br />agency's environmental review obligations "turn[ ] on the value of the new information to <br />75C-32 <br />