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City Response to Comment Letter Lozeau Drury, dated October 10, 2022 <br />Comment 13: This comment provides text from the Project's staff report and states that the <br />subsequent environmental review is required pursuant to CEQA Guidelines 15183, as the <br />Project's GHG analysis is insufficient because the GHG analysis relies upon an outdated <br />quantitative GHG threshold, and the analysis fails to identify a potentially significant GHG impact. <br />Response 13: As detailed in Response 7, the appropriate threshold was utilized in the <br />Community Plan Exemption Checklist, as utilized by many lead agencies in the SCAQMD region. <br />Also, as detailed in Response 8, CEQA gives lead agencies the discretion to determine, in the <br />context of a particular project, how to assess potential GHG impacts. The analysis in the <br />Community Plan Exemption Checklist does not identify a GHG impact because the emissions <br />generated by the Project would not exceed the identified threshold. <br />Comment 14: This comment is consistent with Comment 7, previously. <br />Response 14: Refer to Response 7. <br />Comment 15: This comment is consistent with Comment 8, previously. <br />Response 15: Refer to Response 8. <br />Comment 16: This comment states that the Project would result in potentially significant health <br />risk and GHG <br />impacts that should be mitigated further. The comment lists various several mitigation measures <br />from the Department of Justice Warehouse Project Best Practices document. <br />Response 16: As detailed in previous responses, the Project would not result in potentially <br />significant health risk or GHG impacts. Therefore, no mitigation measures are required. However, <br />many of the suggested measures listed in the comment would be implemented in consistency <br />with the CALGreen Building Code, CARB requirements, SCAQMD Rules, which would be verified <br />by the City during the Project permitting process. <br />Comment 17: This comment states that the previously listed measures offer a cost-effective, <br />feasible way to incorporate lower -emitting design features into the proposed Project, which <br />subsequently, reduce emissions released during Project construction and operation. The <br />comment states that an EIR should be prepared to include all feasible mitigation measures, as <br />well as include updated health risk and GHG analyses to ensure that the necessary mitigation <br />measures are implemented to reduce emissions to below thresholds. <br />Response 17: As detailed in Response 16, the Project would not result in potentially significant <br />health risk or GHG impacts, and no mitigation measures or EIR are required. However, many of <br />the suggested measures would be implemented pursuant to existing regulations, which would be <br />verified by the City during the Project permitting process. <br />Comment 18: This comment states that the commenter has received limited discovery regarding <br />the Project, additional information may become available in the future; and the commentor retains <br />the right to revise or amend this report when additional information becomes available. The <br />Exhibit 13 <br />Page 6of7 <br />