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

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4.8.2 Does the Project propose changes that would result in new significant impacts or substantial increase in the severity of significant impacts that will require major revisions of the Certified EIR? As stated above, the topic of GHG Emissions impacts was not included in the 2007 CEQA Guidelines but is included in the current version of the CEQA Guidelines. Since the approval of the Certified EIR, international agreements, as well as federal and state laws and regulations, have been adopted to reduce GHG emissions. However, both the existence of carbon dioxide and other GHG emissions from fossil fuel combustion and other activities were known at the time the Certified EIR was approved. Therefore, a GHG analysis is not required for the Project. Nevertheless, a detailed analysis of the Project's GHG emissions impacts is included in Attachment D of this document. As summarized below, the Project would not result in any significant impacts related to GHG emissions. Methodology CEQA Guidelines Section 15064.4(a) assists lead agencies in determining the significance of the impacts of GHG emissions, giving them discretion to determine whether to assess impacts quantitatively or qualitatively. It calls for a good -faith effort to describe and calculate emissions. This emissions inventory also demonstrates the reduction in a project's incremental contribution of GHG emissions that results from regulations and requirements adopted as implementation efforts for these plans for the reduction or mitigation of GHG emissions. As such, it provides further justification that a project is consistent with plans adopted for the purpose of reducing and/or mitigating GHG emissions by a project and over time. The significance of a project's GHG emissions impacts is not based on the amount of GHG emissions resulting from that project. The City, SCAQMD, Office of Planning and Research (OPR), CARB, California Air Pollution Control Officers Association (CAPCOA), and other applicable agencies have not adopted a numerical threshold of significance for assessing impacts related to GHG emissions. As a result, the methodology for evaluating a project's impacts related to GHG emissions focuses on its consistency with statewide, regional, and local plans adopted for the purpose of reducing and/or mitigating GHG emissions. The analysis also calculates the amount of GHG emissions from the Project using recommended air quality models. The primary purpose of quantifying the Project's GHG emissions is to satisfy CEQA Guidelines Section 15064.4(a). The estimated emissions inventory is also used to determine if there would be a reduction in the Project's incremental contribution of GHG emissions because of compliance with regulations requirements adopted to implement plans for reducing or mitigating GHG emissions. However, the significance of the Project's GHG emissions is not based on the amount of emissions from the Project as there is no adopted quantified threshold supported by substantial evidence. Attachment D of this document contains a detailed explanation of the methodology underlying this analysis. Cabrillo Town Center City of Santa Ana Technical Memorandum August 2023 City Council 18 — 542 10/3/2023