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December 20, 2022 SAFER Appeal No. 2022-01 of Garry Avenue Business Park Planning Commission Approval City Council Agenda Item 41 (Amendment Application No. 2022-01; Conditional Use Permit No. 2022-14) Page 5 of 5 [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. (Id., pp. 8-9 [citations omitted].) Because it is currently October 2022, thresholds for 2020 are not applicable to the proposed Project and should be revised to reflect the current GHG reduction target. (Id., p. 9.) As a result, the SCAQMD bright -line threshold of 3,000 MT CO2e/year is outdated and inapplicable to the proposed Project, and the [Exemption Checklist's] less -than -significant GHG impact conclusion should not be relied upon. (Exhibit A, p. 9.) Instead, SWAPE recommends "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." (Id.) To more accurately determine the Project's GHG emissions, SWAPE prepared an updated air model using the project -specific information provided by the EA (See, id., pp. 9- 10.) SWAPE's updated analysis demonstrates that the Project would emit approximately 14.6 MT CO2e/SP/year. (Id.) Therefore, the Project's service population efficiency value exceeds the SCAQMD 2035 efficiency target of 3.0 MT CO2e/SP/year, indicating a potentially significant GHG impact not previously identified or addressed by the EA or GPU PEIR. Thus, SWAPE's model demonstrates that the Project would result in a significant GHG impact, which requires the City to prepare a ND or supplemental EIR. Because the Project may have potentially significant greenhouse gas impacts that were not analyzed in the 2022 GPU PEIR, additional CEQA review is required. (14 CCR § 15183 (b)(2)) III. CONCLUSION For the foregoing reasons, SAFER requests that the Planning Commission deny the applications for the Project and, instead, direct city staff to prepare the necessary environmental documents under CEQA. The City should prepare an initial study followed by an EIR or negative declaration in accordance with CEQA prior to consideration of approvals for the Project. Sincerely, Ar�� e � f � µ Victoria Yundt LOZEAU I DRURY LLP