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

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purpose of reducing GHG emissions, included in the applicable portions of the 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 considers 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 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 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 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 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 a Project Without Reduction Features scenarios and from the Project at build -out based on actions and mandates expected to be in force in 2027. 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 GHG emissions. The Project Without Reduction Features scenario does not consider site -specific conditions, project design features, or prescribed mitigation measures. As an example, a Project Without Reduction Features scenario would apply a base ITE trip -generation rate for the project and would not consider site -specific benefits resulting from the proximity to public transportation. Thresholds of Significance State CEQA Guidelines Appendix G In accordance with Appendix G of the State CEQA Guidelines (Appendix G), a project would have a significant impact related to GHG emissions if the project would do the following: a) Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; Cabrillo Town Center Greenhouse. as ec PAGE 31 • • • City of Santa Ana 10/3/2023 July 2023