Item 18 - Appeal Application Nos. 2023-02 and 2023-03 for Cabrillo Town Center project

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of current state mandates, the GHG emissions for the Project would equal 117 MTCO2e annually (as amortized over 30 years) during construction. Estimated Reduction of Project -Related GHG Emissions Resulting from Consistency with Plans As noted earlier, one approach to demonstrating a project's consistency with GHG plans is to show how a project will reduce its incremental contribution through a Project Without Reduction Features comparison. The analysis in this section includes potential emissions under a Project Without Reduction Features scenario and from the Project at build -out based on actions and mandates in force in 2027. As shown in Table 10, the emissions for the Project and its associated CARB 2027 Project Without Reduction Features scenario are estimated to be 4,639 and 6,721 MTCO2e per year, respectively, which shows the Project would reduce emissions by 31 percent from CARB's 2027 Project Without Reduction Features scenario. Table 10 Estimated Reduction of Project -Related GHG Emissions Resulting from Consistency with Plans Reduction from Change from Project Without As Project Without Project Without Reduction Scenario and Source Proposed Reduction Reduction Features Scenario Features Features Scenario* Scenario Scenario Area Sources 19 19 - 0% Energy Sources 1,566 908 -658 -42% Mobile Sources 4,779 3,355 -1,424 -30% Waste Sources 186 186 - 0% Water Sources 53 53 - 0% Refrigerants 1 1 - 0% Construction 117 117 - 0% Total Emissions 6,721 4,639 -2,082 -31.0% Daily construction emissions amortized over 30-year period pursuant to SCAQMD guidance. Annual construction emissions derived by taking total emissions over duration of activities and dividing by construction period. * Project Without Reduction Features scenario does not assume 30% reduction in in mobile source emissions from Pavley emission standards (19.8%), low carbon fuel standards (7.2%), vehicle efficiency measures 2.8%); does not assume 42% reduction in energy production emissions from the State's renewables portfolio standard (33%), natural gas extraction efficiency measures (1.6%), and natural gas transmission and distribution efficiency measures (7.451o). Source: DKA Planning, 2023. The analysis in this section uses the 2022 Scoping Plan's statewide goals as one approach to evaluate the Project's incremental contribution to climate change. The methodology is to compare the Project's emissions as proposed to the Project's emissions as if the Project were built using a Project Without Reduction Features approach in terms of design, methodology, and technology. Cabrillo Town Center PAGE 55 18 — 1020 City of Santa Ana 10/3/20 2123