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

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South Coast Technology Center Project CEQA Exemption 15183 thresholds to qualitative significance thresholds that focus on project features to reduce GHG emissions or consistency with GHG reduction plans. For example, in the Bay Area Air Quality Management District (BAAQMD) 2022 CEQA Guidelines, the GHG thresholds of significance are either whether land use projects include certain project design elements related to buildings and transportation or whether the project is consistent with a local GHG reduction strategy that meets the criteria under State CEQA Guidelines Section 15183.5(b). This is a major update to BAAQMD's 2017 CEQA Guidelines, where a numerical significance threshold was required. To reduce GHG emissions impact, it is more effective for development projects to include project features that directly or indirectly reduce GHG emissions, than relying on a numerical significance threshold, which is highly dependent on the type and size of the development. Therefore, the significance of the Project's potential impacts regarding GHG emissions and climate change is assessed solely on its consistency with plans and policies adopted for the purposes of reducing GHG emissions and mitigating the effects of climate change and the Project's ability to incorporate sustainable features and strategies from such plans and policies in its design to reduce GHG emissions. The analysis has also quantified the Project's GHG emissions and compared them to the SCAQMD bright -line screening thresholds for informational purposes. It should be noted that individual projects do not generate sufficient GHG emissions to directly influence climate change. However, physical changes caused by a project can contribute incrementally to significant cumulative effects, even if individual changes resulting from a project are limited. As a result, the issue of climate change typically involves an analysis of whether a project's contribution towards an impact would be cumulatively considerable. According to CEQA Guidelines Section 15064(h)(1), "cumulatively considerable" means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects. Per CEQA Guidelines Section 15064(h)(3), a project's incremental contribution to a cumulative impact can be found not cumulatively considerable if the project would comply with an approved plan or mitigation program that provides specific requirements that would avoid or substantially lessen the cumulative problem in the geographic area of the project. To qualify, such plans or programs must be specified in law or adopted by the public agency with jurisdiction over the affected resources through a public review process to implement, interpret, or make specific the law enforced or administered by the public agency. Examples of such programs include a water quality control plan, air quality attainment or maintenance plan, integrated waste management plan, habitat conservation plan, natural community conservation plans, and plans or regulations for the reduction of GHG emissions. Therefore, a lead agency can make a finding of less than significant for GHG emissions if a project complies with adopted programs, plans, policies, and/or other regulatory strategies to reduce GHG emissions. PROJECT -RELATED GHG EMISSIONS As discussed above, the Project's GHG emissions are quantified for informational purposes only as neither the City, nor any other public agency, has an applicable numeric significance threshold for GHG emissions. CaIEEMod was used to model the GHG emissions from existing buildings and to calculate project -related GHG emissions, including direct and indirect GHG emissions. Table 4.8-1, Existing Greenhouse Gas Emissions, presents the current GHG emission from the existing buildings. July 2024 Page 52