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8 <br /> <br />As demonstrated above, a Project is ineligible for an exemption pursuant to CEQA Guidelines § 15183 if <br />“there are project-specific significant effects which are peculiar to the project or its site.” The City <br />determined that the Project would not result in any new significant effects not discussed in the GPU EIR. <br />Furthermore, the EA concludes the Project would have a less-than-significant greenhouse gas (“GHG”) <br />impact (p. 2-99 – 2-100). However, these claims are incorrect and subsequent environmental review is <br />required pursuant to CEQA Guidelines 15183, as the Project’s GHG analysis is insufficient for the <br />following two reasons: <br />(1) The EA’s GHG analysis relies upon an outdated quantitative GHG threshold; and <br />(2) The EA’s GHG analysis fails to identify a potentially significant GHG impact. <br />1) Incorrect Reliance on an Outdated Quantitative GHG Threshold <br />The EA estimates that the Project would generate net annual greenhouse gas (“GHG”) emissions of <br />1,668 metric tons of carbon dioxide equivalents per year (“MT CO2e/year”), which would not exceed the <br />SCAQMD threshold of 3,000 MT CO2e/year (see excerpt below) (p. 2-99, Table GHG-2). <br /> <br />However, the guidance that provided the 3,000 MT CO2e/year threshold, the SCAQMD’s 2008 Interim <br />CEQA GHG Significance Threshold for Stationary Sources, Rules, and Plans report, was developed when <br />the Global Warming Solutions Act of 2006, commonly known as “AB 32”, was the governing statute for <br />GHG reductions in California. AB 32 requires California to reduce GHG emissions to 1990 levels by <br />2020.17 Furthermore, AEP guidance states: <br /> <br />17 “Health & Safety Code 38550.” California State Legislature, January 2007, available at: <br />https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=HSC&sectionNum=38550.