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

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evaluation is the sole basis pursuant to CEQA for determining the significance of a project's GHG-related impacts on the environment. 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. Consistency with Applicable Plans and Policies A consistency analysis has been provided that describes the Project's compliance with or exceedance of performance -based standards, and consistency with applicable plans and policies adopted for the purpose of reducing GHG emissions, included in the applicable portions of the 2022 Climate Change Scoping Plan, the 2020-2045 RTP/SCS, and the City's CAP. As part of the Climate Change Scoping Plan, a statewide emissions inventory was developed as required by AB 32 which directs CARB to develop and track GHG emissions reductions to document progress towards the state GHG target. The emissions inventory also takes into account GHG emissions reduction measures developed by CARB to achieve state targets. Consistency with the Climate Change Scoping Plan is evaluated by comparing the Project's GHG emissions reduction measures to those contained in the Scoping Plan. As noted in CEQA Guidelines Section 15064.4(b)(3), consistency with such plans and policies "must reduce or mitigate the project's incremental contribution of greenhouse gas emissions." To demonstrate such incremental reductions, this chapter estimates reductions of Project -related GHG emissions resulting from consistency with plans. Consistent with evolving scientific knowledge, approaches to GHG emissions quantification may continue to evolve in the future. While there are many ways to quantify the efficiency of the GHG reduction measures provided for in the plans and policies, this analysis compares the Project's GHG emissions to the emissions that would be generated by the Project in the absence of any GHG emissions reduction measures (i.e., the Project Without Reduction Features Scenario. This approach is consistent with the concepts used in CARB's 2022 Climate Change Scoping Plan. This methodology is used to analyze consistency with applicable GHG emissions reduction plans and policies and demonstrate the efficacy of the measures contained therein, but it is not a threshold of significance. The analysis in this section includes potential emissions under the Project Without Reduction Features scenarios and from the Project at build -out based on actions and mandates expected to be in force in 2026. Early -action measures identified in the Climate Change Scoping Plan that have not been approved were not credited in this analysis. By not speculating on potential regulatory conditions, the analysis takes a conservative approach that likely overestimates the Project's GHG emissions at build -out. The Project Without Reduction Features scenario is used to establish a comparison with project -generated Cabrillo Town Center Greenhouse. as ec PAGE 25 ••1 City of Santa Ana 10/3/2023 July 2023