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

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As shown in Table 13, when taking into consideration implementation of project design features, including the requirements set forth in the City's Green Building Code and the full implementation of current state mandates, the GHG emissions for the Project would equal 117 MTCO2e annually (as amortized over 30 years) during construction. Consistency with Applicable Plans and Policies The discussion below describes the extent to which the Project is consistent with or exceeds the performance -based standards included in the regulations outlined in the 2022 Climate Change Scoping Plan, the 2020-2045 RTP/SCS, and the City's CAP. As discussed below, the Project would be substantially consistent with all applicable plans, policies, and regulations related to reduction of GHG emissions. This consistency analysis is provided for informational purposes only given that, although GHG emissions impacts were known and recognized when the City adopted the Certified EIR, these GHG emissions reduction plans and policies did not exist at that time. 6,4MM- 1 OMMIRM9111 iFWNilI'fTit:[1F. • �• Z!F1i1 The goal to reduce GHG emissions to 1990 levels by 2020 (Executive Order S-3-05) was codified by the Legislature as the 2006 Global Warming Solutions Act (AB 32). In 2008, CARB approved a Climate Change Scoping Plan as required by AB 32 that has been updated over time to reflect updated strategies. In addition, SB 32 was approved in 2016, calling for deeper GHG emissions reductions by 2030. The 2022 Climate Change Scoping Plan addresses the 2030 horizon but also addresses the objective of carbon neutrality by 2045 and has a range of GHG emissions reduction actions that include direct regulations, alternative compliance mechanisms, monetary and non - monetary incentives, voluntary actions, market -based mechanisms such as a cap -and -trade system, and an AB 32 implementation fee to fund the program. The following discussion demonstrates how the pertinent reduction actions relate to and reduce project -related GHG emissions. Table 14 evaluates the Project's consistency with applicable reduction actions/strategies by emissions source category outlined in the 2022 Climate Change Scoping Plan Update. When compared to SB 32, the Project would be substantially consistent with its objectives and the GHG reduction -related actions and strategies of the 2022 Scoping Plan. Table 14 confirms that the Project is consistent with the Scoping Plan's focus on increasing renewable energy use, putting more electric cars on the road, and improving energy efficiency. Although a number of these strategies are currently promulgated, some have not yet been formally proposed or adopted. It is expected that these measures or similar actions to reduce GHG emissions will be adopted as required to achieve statewide GHG emissions targets. Independent studies confirm CARB's determination that the state's existing and proposed regulatory framework will put the state on a pathway to reduce its GHG emissions level to 40 percent below 1990 levels by 2030, and to 85 percent below 1990 levels by 2045 to meet carbon neutrality objectives if additional appropriate reduction measures are adopted. Even though these studies did not provide an exact regulatory and technological roadmap to achieve the 2030 and Cabrillo Town Center City of Santa Ana Technical Memorandum August 2023 City Council 18 — 548 10/3/2023