Item 28 - Public Hearing - ZOA No. 20204-01 South Coast Technology Center

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South Coast Technology Center Project CEQA Exemption 15183 Plan, SCAG 2020-2045 RTP/SCS, the City's CAP, and, as such, impacts related to consistency with plans, policies, and regulations adopted for the purpose of reducing GHG emissions would be less than significant. 4.8.2 Project Analysis The following section evaluates the potential GHG impacts that would result from implementation of the proposed Project. This analysis is primarily based upon Attachment F, Greenhouse Gas Emissions Assessment. SIGNIFICANCE CRITERIA AND METHODOLOGY The significance determination for Impact 5.7-1 of the GPU PEIR focused on whether programmatic buildout of the General Plan Update would meet the long-term GHG reduction goal under Executive Order S-03-05, which does not fully align with the project -specific analysis presented below. However, as mentioned in the GPU PEIR, if specific project developments would result in emissions below the 3,000 MTCO2e bright -line threshold, impacts would be considered less than significant. CEQA Guidelines Section 15064.4 recommends that lead agencies quantify GHG emissions of projects and consider several other factors that may be used in the determination of significance of GHG emissions from a project, including the extent to which the project may increase or reduce GHG emissions, whether a project's emissions exceeds an applicable significance threshold, and the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. However, CEQA Guidelines Section 15064.4 does not establish a threshold of significance. CEQA Guidelines Section 15064.7 provides lead agencies the discretion to establish significance thresholds for their respective jurisdictions, and in establishing those thresholds, a lead agency may appropriately look to thresholds developed by other public agencies or suggested by other experts, if any threshold chosen is supported by substantial evidence. The City has adopted a CAP; however, the CAP does not contain a numerical significance threshold for assessing impacts related to GHG emissions. Similarly, the SCAQMD, the Governor's Office of Planning and Research, CARB, California Air Pollution Control Officers Association (CAPCOA), or any other state or applicable regional agency has yet to adopt a numerical significance threshold for assessing GHG emissions that is applicable to the Project. The SCAQMD formed a GHG CEQA Significance Threshold Working Group (Working Group) to provide guidance to local lead agencies on determining significance for GHG emissions in their CEQA documents and was proposing to adopt a tiered approach for evaluating GHG emissions for development projects where SCAQMD is the lead agency as of the last Working Group meeting (Meeting No.15) held in September 2010; the Working Group identified a "bright -line" screening -level threshold of 3,000 MTCO2e annually for new development projects in the residential/commercial sectors and a threshold of 10,000 MTCO2e annually for industrial projects, which includes construction emissions amortized over 30 years and added to operational GHG emissions. However, the proposed thresholds were based on the State's GHG emissions reduction goal identified in Assembly Bill (AB) 32 for the year 2020, which is outdated, and SCAQMD never formally adopted the 3,000 MTCO2e threshold for new residential and commercial projects. The 10,000 MTCO2e threshold was adopted for industrial projects where SCAQMD is the lead agency. Impacts of climate change are experienced on a global scale regardless of the location of GHG emission sources, and therefore, a numerical significance threshold for individual development projects is speculative. Throughout the State, air districts are moving from numerical significance July 2024 Page 51