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

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GHG emissions associated with solid waste disposal are based on the size of the Project's proposed land uses, the waste disposal rate for the land uses, the waste diversion rate, the GHG emission factors for solid waste decomposition, and the GWP values for the GHG emissions emitted. GHG emissions related to water usage and wastewater generation are based on the size of the land uses, the water demand factors, the electrical intensity factors for water supply, treatment, and distribution, electrical intensity factors for wastewater treatment, the GHG emission factors for the electricity utility provider, and the GWP values for the GHG emissions emitted. The analysis of Project GHG emissions at buildout uses assumptions in CARB's EMFAC2021 model (1.0.1) and considers actions and mandates expected to be in force when the Project is operational (e.g., Pavley I Standards, full implementation of California's 33 percent RPS by 2030 and 50 percent by 2050 and the California LCFS). In addition, because mobile source GHG emissions are directly dependent on the number of vehicle trips, a decrease in the number of project -generated trips because of project features (e.g., proximity to transit) would provide a proportional reduction in mobile source GHG emissions compared to a generic project without such Iocational benefits. Calculation of Project GHG emissions conservatively did not include actions and mandates that are not already in place but are expected to be enforced when the Project is operational (e.g., Pavley 11, which could further reduce GHG emissions from use of light -duty vehicles by 2.5 percent). Similarly, emissions reductions regarding Cap -and -Trade were not included in this analysis as they applied to other future reductions in non - transportation sectors. As for the Cap -and -Trade program's benefits for the transportation sector, the analysis utilizes CARB's assumptions in EMFAC2021 for any short-term reductions in GHG emissions. By not speculating on potential regulatory conditions, the analysis takes a conservative approach that likely overestimates the Project's GHG emissions at buildout, because the state is expected to implement several policies and programs aimed at reducing GHG emissions from the land use and transportation sectors to meet the state's long-term climate goals. There are no GHG emissions thresholds adopted by the SCAQMD that are applicable to the Project. In 2008, SCAQMD released draft guidance regarding interim CEQA GHG significance thresholds.68 Within its October 2008 document, the SCAQMD proposed the use of a percent emission reduction target to determine the significance for commercial/residential projects that emit greater than 3,000 MTCO2e per year. Under this proposal, such commercial and residential projects would have been assumed to have a less than significant impact on climate change. However, this proposed screening threshold was not adopted by the SCAQMD. 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 Cabrillo Town Center Greenhouse. as ec PAGE 30 18 — 995 City of Santa Ana 10/3/2023 July 2023