Item No. 2 Public Comment_Yundt - Laserfiche WebLink

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9 “[F]or evaluating projects with a post 2020 horizon, the threshold will need to be revised based on a new gap analysis that would examine 17 development and reduction potentials out to the next GHG reduction milestone.”18 As it is currently September 2022, thresholds for 2020 are not applicable to the proposed Project and should be revised to reflect the current GHG reduction target. As such, the SCAQMD bright-line threshold of 3,000 MT CO2e/year is outdated and inapplicable to the proposed Project, and the EA’s less-than-significant GHG impact conclusion should not be relied upon. Instead, we recommend that the Project apply the SCAQMD 2035 service population efficiency target of 3.0 metric tons of carbon dioxide equivalents per service population per year (“MT CO2e/SP/year”), which was calculated by applying a 40% reduction to the 2020 targets.19 2) Failure to Identify a Potentially Significant GHG Impact In an effort to quantitatively evaluate the Project’s GHG emissions, we compared the Project’s GHG emissions, as estimated by the EA, to the SCAQMD 2035 efficiency target of 3.0 MT CO2e/SP/year. When applying this threshold, the Project’s air model indicates a potentially significant GHG impact. As previously stated, the EA estimates that the Project would generate net annual GHG emissions of 1,668 MT CO2e/year (p. 2-99, Table GHG-2). According to CAPCOA’s CEQA & Climate Change report, a service population (“SP”) is defined as “the sum of the number of residents and the number of jobs supported by the project.”20 The EA indicates that the Project would generate approximately 114 jobs (p. 2-124). As the proposed Project does not include any residential land uses, we estimate a SP of 114 people. When dividing the Project’s net annual GHG emissions, as estimated by the EA, by a SP of 114 people, we find that the Project would emit approximately 14.6 MT CO2e/SP/year (see table below).21 EA Greenhouse Gas Emissions Annual Emissions (MT CO2e/year) 1,668 Service Population 114 Service Population Efficiency (MT CO2e/SP/year) 14.6 SCAQMD 2035 Target 3.0 Exceeds? Yes 18 “Beyond Newhall and 2020: A Field Guide to New CEQA Greenhouse Gas Thresholds and Climate Action Plan Targets for California.” Association of Environmental Professionals (AEP), October 2016, available at: https://califaep.org/docs/AEP-2016_Final_White_Paper.pdf, p. 39. 19 “Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15.” SCAQMD, September 2010, available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa- significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf, p. 2. 20 “CEQA & Climate Change.” California Air Pollution Control Officers Association (CAPCOA), January 2008, available at: http://www.capcoa.org/wp-content/uploads/2012/03/CAPCOA-White-Paper.pdf, p. 71-72. 21 Calculated: (1,668 MT CO2e/year) / (114 service population) = (14.6 MT CO2e/SP/year).