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SANTA ANA REZONE PROJECT <br />INITIAL STUDY/MITIGATED NEGATIVE DECLARATION <br />CO2e annually for all land use types.41,41 However, the proposed threshold was based on the State's <br />GHG emissions reduction goal identified in AB 32 for the year 2020, which has been outdated, and <br />SCAQMD never adopted the threshold. Impacts of climate change are experienced on a global scale <br />regardless of the location of GHG emission sources; therefore, a numerical significance threshold for <br />individual development projects is speculative. Throughout the State, air districts are moving from <br />numerical significance thresholds to qualitative significance thresholds that focus on project features <br />to reduce GHG emissions or consistency with GHG reduction plans. For example, in the Bay Area Air <br />Quality Management District's (Bay Area Air District) 2022 CEQA Guidelines, the GHG thresholds of <br />significance are either whether land use projects include certain project design elements related to <br />buildings and transportation or whether the project is consistent with a local GHG reduction strategy <br />that meets the criteria under CEQA Guidelines Section 15183.5(b). This is a major update to Bay <br />Area Air District's 2017 CEQA Guidelines, where a numerical significance threshold was required. To <br />reduce GHG emissions impact, it is more effective for development projects to include project <br />features that directly or indirectly reduce GHG emissions than to rely on a numerical significance <br />threshold, which highly depends on the type and size of the development. Therefore, the significance <br />of the proposed project's potential impacts regarding GHG emissions and climate change will be <br />assessed solely on its consistency with plans and policies adopted for the purposes of reducing GHG <br />emissions and mitigating the effects of climate change. <br />Would the project: <br />a) Generate greenhouse gas emissions, either directly or indirectly, that may have a <br />significant impact on the environment? <br />Less than significant impact. The proposed project would generate GHG emissions during <br />construction and operation (e.g., mobile emissions, emission from the manufacturing and transport of <br />building materials during construction, and emissions from generation of electricity for operations). <br />The proposed project's construction and operational emissions are presented below for information <br />purposes. <br />Construction GHG Emissions <br />During project construction, GHGs would be generated by construction activities, such as site <br />clearing, operation of heavy-duty construction vehicles, materials and debris hauling, paving, and <br />construction worker vehicle trips. These emissions would be considered short-term in duration. <br />Construction emissions were estimated using California Emissions Estimator Model (CalEEMod). <br />Construction assumptions used to estimate GHG emissions are consistent with those used to <br />South Coast Air Quality Management District (SCAQMD). 2008. Board Letter — Interim CEQA GHG Significance <br />Threshold for Stationary Sources, Rules and Plans. Website:https://www.aqmd.gov/docs/default- <br />source/cega/handbook/greenhouse-gases-(ghg)-cega-significance-thresholds/ghg board synopsis. pdf. Accessed July 25, <br />2025. <br />42 South Coast Air Quality Management District (SCAQMD). 2010. Minutes for the GHG CEQA Significance Threshold <br />Stakeholder Working Group #15. Websitehttps://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases- <br />(ghg)-cega-significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf. Accessed July 25, <br />2025. <br />58 FCS <br />Https://adecinnovaticns.sharepoint.com/sites/PubiicationsSite/Shared Documents/Publications/Client(PN-JN)/0327/03270047/ISMND/03270047 Santa Ana Rezone Project ISMND.docx <br />