Item 27 - Appeal Application Nos. 2020-03 and 2020-04 - Central Pointe Mixed-Use Development

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"Projects with a horizon year (e.g. the year in which the proiect is fully realized) beyond 2020 should not tier from a GHG reduction plan that may be qualified up to 2020 but is not yet qualified for a post-2020 period" (emphasis added).20 As you can see in the excerpt above, projects that will become operational beyond 2020 should not tier from CAPS only qualified up to 2020. Given that it is already November 2020 and the Project has yet to be approved, we know that the Project will not become operational by 2020. Thus, the City's CAP is now outdated and inapplicable to the proposed Proiect, as it should not be relied upon to determine the significance of GHG impacts beyond 2020. Thus, the Project's reliance on the 2018 DSEIR, as well as the subsequent less -than -significant impaction conclusion, is incorrect, as the Project's post-2020 GHG emissions require updated analysis. Second, the Project's GHG emissions indicate a potentially significant GHG impact when applying the SCAQMD efficiency threshold of 3.0 MT CO2e/year for the year 2035, which was calculated based on a 40% reduction from the 2020 GHG efficient target .21 The CalEEMod output files, modeled by SWAPE with Project -specific information, disclose the Project's GHG emissions, which include approximately 1,553 MT CO2e/year of construction -related emissions (sum of 2020, 2021, and 2022) and 7,915 MT CO2e/year of annual operational emissions (sum of area, energy, mobile, waste, and water -related emissions). Furthermore, the Staff Report indicates that the Project would generate a service population of 1,399 people (p. 1-258). Dividing the Project's GHG emissions, as estimated by the SWAPE, by a service population value of 1,399 people, we find that the Project would emit approximately 5.7 MT CO2e/SP/year (see table below).zz 21 "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. 38. u "Minutes for the GHG CECA Significance Threshold Stakeholder Working Group #15." SCAQMD, September 2010, available at: http://www.agmd.gov/docs/default-source/cega/handbook/greenhouse-gases-(ghg)-cega- significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf, p. 2. 22 Calculated: (7,966 MT CO2e/year) / (1,399 service population) = (5.7 MT CO2e/SP/year). 14