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emissions over the 1990level by the end of 2030. As a result, the Project should comply with SB 32, which requires a more aggressive GHG threshold. Thus, we recommend that the Project rely upon the SCAQMD efficiency threshold of 3.0 MT CO,e/year for the year 2035, which was calculated based on a 40% reduction from the 2020 GHG efficient target.38 By failing to compare the Project's estimated GHG emissions to the SCAQMD GHG threshold, the Addendum leaves a gap in its quantitative GHG analysis. (4) Failure to Identify a Potentially Significant GHG Impact The Addendum's incorrect and unsubstantiated air model indicates a potentially significant GHG impact, when applying the relevant SCAQMD efficiency threshold of 3.0 MT CO,e/year for the year 2035.39 Specifically, the Addendum estimates that the Project would generate net annual GHG emissions of 1,493 MT CO2e/year (p. 3.5-2, Table 3.5-1). Furthermore, as described above, we estimate that the Project's service population would be 430 people. Dividing the Project's GHG emissions, as estimated by the Addendum, by a service population value of 430 people, we find that the Project would emit approximately 3.47 MT CO2e/SP/year (see table below).41 Addendum Service Population Efficiency Project Phase Proposed Project (MT CO2e/year) Total 1493.00 Service Population 430 Service Population Efficiency 3.47 Threshold Exceed? 3.0 Yes When we compare the Project's per service population GHG emissions to the SCAQMD 2035 efficiency target of 3.0 MT CO2e/SP/year, we find that the Project would result in a significant GHG impact not previously identified or addressed by 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. Therefore, a Project -specific EIR should be prepared and recirculated for the Project, and mitigation should be implemented where necessary, per CEQA Guidelines. (S) Incorrect Reliance on the City's CAP As previously mentioned, the Addendum relies upon the Project's consistency with the City's CAP in order to conclude that the Project would result in a less than significant GHG impact (p. 3.5-3 - 3.5-3). ""Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15." SCAQMD, September 2010, available at: http://www.agmd.gov/docs/default-source/cega/handbook/greenhouse-gases-(ghg)-cega- significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf, p. 2. 39 "Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15." SCAQMD, September 2010, available at: http://www.agmd.gov/docs/default-source/cega/handbook/greenhouse-gases-(ghg)-cega- significance-thresholds/year-2008-2009/aha-meeting-15/aha-meeting-15-minutes.adf, p. 2. 40 Calculated: (1,493 MT CO2e/year) / (430 service population) = (3.47 MT CO2e/SP/year). 23 75C-98