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Comment on Garry Avenue Business Park Project <br />Planning Commission Agenda Item 2 (Amendment Application No. 2022-01; Conditional Use Permit No. 2022-14) <br />October 10, 2022 <br />Page 7 of 7 <br />[F]or evaluating projects with a post 2020 horizon, the threshold will need to be <br />revised based on a new gap analysis that would examine 17 development and <br />reduction potentials out to the next GHG reduction milestone. <br />(Id., pp. 8-9 [citations omitted].) Because it is currently October 2022, thresholds for 2020 are <br />not applicable to the proposed Project and should be revised to reflect the current GHG <br />reduction target. (Id., p. 9.) As a result, the SCAQMD bright -line threshold of 3,000 MT <br />CO2e/year is outdated and inapplicable to the proposed Project, and the [Exemption <br />Checklist's] less -than -significant GHG impact conclusion should not be relied upon. (Exhibit A, <br />p. 9.) Instead, SWAPE recommends "that the Project apply the SCAQMD 2035 service <br />population efficiency target of 3.0 metric tons of carbon dioxide equivalents per service <br />population per year ("MT CO2e/SP/year"), which was calculated by applying a 40% reduction <br />to the 2020 targets." (Id.) <br />To more accurately determine the Project's GHG emissions, SWAPE prepared an <br />updated air model using the project -specific information provided by the Exemption Checklist. <br />(See, id., pp. 9-10.) SWAPE's updated analysis demonstrates that the Project would emit <br />approximately 14.6 MT CO2e/SP/year. (Id.) Therefore, the Project's service population <br />efficiency value exceeds the SCAQMD 2035 efficiency target of 3.0 MT CO2e/SP/year, <br />indicating a potentially significant GHG impact not previously identified or addressed by the <br />Exemption Checklist or GPU EIR. Thus, SWAPE's model demonstrates that the Project would <br />result in a significant GHG impact, which precludes reliance on the CEQA Section 15183 <br />exemption. <br />CONCLUSION <br />For the foregoing reasons, SAFER requests that the Planning Commission deny the <br />applications for the Project and, instead, direct city staff to prepare the necessary environmental <br />documents under CEQA. The City should prepare an initial study followed by an EIR or <br />negative declaration in accordance with CEQA prior to consideration of approvals for the <br />Project. <br />Sincerely, <br />Victoria Yundt <br />LOZEAU I DRURY LLP <br />