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However, review of the City's CAP demonstrates that the CAP is designed to help the City achieve it's 2020 GHG reduction goal and needs to be updated in order to meet the City's 2035 GHG reduction goal.41 Specifically, the CAP states: "The measures in this CAP are projected to accomplish the goal of a 15% reduction in community -wide emissions bv2020, and to nearly reach the 30% reduction by 2035 goal, as shown in Figure 3.1. It is anticipated that new policy and technology options for reducing emissions may become available before 2035; the CAP will need to be updated and additional measures mayneed to be added to meet the 2035 goal. The CAP measures affecting municipal operations are projected to accomplish both the 30% reduction by 2020 goal and the 40% reduction by 2035 goal" (emphasis added).41 As such, the City of Santa Ana's CAP is only applicable to projects that will be fullyoperational bv2020, as the CAP should be updated to meet the City's 2035 GHG reduction goal. Given that it is already October 2020 and the Project has yet to be approved, we know that the Project will not become operational by 2020. Thus, the City's CAP is inapplicable to the proposed Project, and the Addendum's reliance upon the City's CAP is incorrect. As a result, the Addendum's less than significant impact conclusion regarding the City's CAP should not be relied upon. (6) Failure to Demonstrate Consistency with CARB's 2017Scoping Plan As discussed above, the Addendum relies upon the Project's consistency with the CARB's 2017 Scoping Plan in order to conclude that the Project would result in a less than significant GHG impact (p. 3.5-3 - 3.5-4). However, review of CARB's 2017 Scoping Plan reveals that the proposed Project is inconsistent with numerous measures, including but not limited to the analysis below: Measures — Construction Require construction vehicles to operate with the Here, the Addendum states that "[a]pplicable highest tier engines commercially available construction mitigation measures include all diesel fuel construction equipment classified U.S. Environmental Protection Agency (U.S. EPA) Tier II or better" (p. 3.5-1). However, Tier 4 Final engines are the highest tier commercially available. As such, the Project fails to require construction vehicles to operate with the highest tier engines commercially available, as the measure requires. Furthermore, the Addendum fails to evaluate the 41 "Santa Ana Climate Action Plan." ICLEI-USA, December 2015, available at: https://www.santa- ana.org/sites/default/files/Documents/climate action plan.pdf, p. 26. 42 "Santa Ana Climate Action Plan." ICLEI-USA, December 2015, available at: https://www.santa- ana.org/sites/default/files/Documents/climate action plan.pdf, p. 26. 43 California Air Resources Board ("CARB") (Jan. 2017) 2017 Scoping Plan, Appendix B-Local Action, availableat: htti)s://ww3.arb.ca.gov/cc/scoi)ingi)lan/2030si) appb localaction final.pdf, p. 8-10. 24 75C-99