iv.f. greenhouse gas emissions (academy square) · city(of(los(angeles(( march(2016...

Academy Square Project IV.F. Greenhouse Gas Emissions Page IV.F-‐1

IV. ENVIRONMENTAL IMPACT ANALYSIS F. GREENHOUSE GAS EMISSIONS

1. INTRODUCTION

This section evaluates the potential impacts of the Project on greenhouse gas (GHG) emissions. GHGs are emitted by both natural processes and human activities. The accumulation of GHGs in the atmosphere regulates the earth’s temperature. The State of California has undertaken initiatives designed to address the effects of GHGs, and to establish targets and emission reduction strategies for GHG emissions in California. This analysis incorporates information in the Greenhouse Gas

Technical Report, Academy Square Project, Los Angeles, California (included as Appendix G to this Draft EIR).

There are several unique challenges to analyzing greenhouse gas emissions and climate change under the California Environmental Quality Act (CEQA), largely because of the global nature of climate change. Typical CEQA analyses address local actions that have local – or, at most, regional – impacts, whereas climate change presents the considerable challenge of analyzing the relationship between local activities and the resulting potential, if any, for global environmental impacts. Most environmental analyses examine the “project-‐specific” impacts that a particular project is likely to generate. With regard to global climate change, however, it is generally accepted that while the magnitude of global warming effects is substantial, the contribution of an individual general development project is so small that direct project-‐specific significant impacts (albeit not cumulative significant impacts) are highly unlikely.

Global climate change is also fundamentally different from other types of air quality impact analyses under CEQA in which the impacts are all measured within, and are linked to, a discrete region or area. Instead, a global climate change analysis must be considered on a global level, rather than the typical local or regional setting, and requires consideration of not only emissions from the project under consideration, but also the extent of the displacement, translocation, and redistribution of emissions. In the usual context, where air quality is linked to a particular location or area, it is appropriate to consider the creation of new emissions in that specific area to be an environmental impact whether or not the emissions are truly “new” emissions to the overall globe. When the impact is a global one, however, it makes more sense to consider whether the emissions really are new emissions, or are merely being moved from one place to another. For example, the approval of a new developmental plan or project does not necessarily create new automobile drivers -‐ the primary source of a land use project’s emissions. Rather, due to the “relocation” factor, new land use projects often merely redistribute existing mobile emissions;1 accordingly, the use of models that measure overall emissions increases without accounting for existing emissions will substantially overstate the impact of the development project on global warming. This makes an accurate analysis of GHG emissions substantially different 1 For example, a new subdivision of 500 homes generates 5,000 new trips per day and those trips would be

added to the local streets and intersections. Trips that are associated with those homes presumably would emit roughly the same volume of GHGs in the City as they would if they were traveling the same number of miles in Cleveland, Ohio. While raw vehicle trip counts accurately predict changes in congestion at intersections, the same certainty cannot be provided for climate change. The trips would certainly increase the number of vehicles passing through local intersections, but they will not increase the amount of GHG emissions into the world’s atmosphere if those trips simply have been relocated from another location on the planet.

Gases that trap heat in the atmosphere are called greenhouse gases.

City of Los Angeles March 2016


from other air quality impacts, where the “addition” of redistributed emissions to a new locale can make a substantial difference to overall air quality.

2. ENVIRONMENTAL SETTING

A. Global Climate Change

The earth’s natural warming process is known as the “greenhouse effect.” Certain atmospheric gases act as an insulating blanket for solar energy to keep the global average temperature in a suitable range for life support. The greenhouse effect raises the temperature of the earth’s surface by about 60 degrees Fahrenheit. With the natural greenhouse effect, the average temperature of the earth is about 45 degrees Fahrenheit; without it, the earth would be about minus 15 degrees. It is normal for the earth’s temperature to fluctuate over extended periods of time. Over the past one hundred years, the earth’s average global temperature has generally increased by one degree Fahrenheit. In some regions of the world, the increase has been as much as four degrees Fahrenheit.

Scientists studying the particularly rapid rise in global temperatures during the late twentieth century believe that natural variability alone does not account for that rise. Rather, human activity spawned by the industrial revolution has likely resulted in increased emissions of carbon dioxide and other forms of GHGs, primarily from the burning of fossil fuels (i.e., during motorized transport, electricity generation, consumption of natural gas, industrial activity, manufacturing, etc.) and deforestation, as well as agricultural activity and the decomposition of solid waste.

The principal GHGs are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), perfluorocarbons (PFCs), hydrofluorocarbons (HFCs), and water vapor (H2O). The most common GHG is carbon dioxide (CO2), which constitutes approximately 84 percent of all GHG emissions in California.2 Worldwide, the State of California ranks as the 12th to 16th largest emitter of CO2 and is

responsible for approximately two percent of the world’s CO2 emissions.3 CO2 is the reference gas for climate change because it is the predominant GHG emitted. To account for the varying warming potential of different GHGs, GHG emissions are often quantified and reported as CO2 equivalents (CO2e).

B. Existing Conditions

Existing land uses within the Project Site include three commercial buildings with a total of approximately 42,763 square feet of floor area, surface parking areas, and lawn areas. The existing buildings are currently used as creative office space. The criteria pollutant emissions from these existing land uses were estimated using CalEEMod as shown in Table IV.F-‐1 (Existing Conditions GHG Emissions).

2 California Energy Commission, 2006. 3 California Energy Commission, 2006.

GHG emissions are quantified as CO2e.



Table IV.F-‐1 Existing Conditions GHG Emissions

Categorya CO2e Emissionsb

(MT/year)

Area 0.004 Energy Use 413 Water Use 94 Waste Disposal 18 Traffic 834

Total 1,359 Notes: MT/year = metric tons per year a CO2e emissions were estimated using CalEEMod version 2013.2.2 for all operational categories. This estimate is based on existing land uses, existing water use estimates, and trip rates estimated by Fehr & Peers. b CO2e includes CO2, CH4, and N2O emissions, which are weighted by their respective global warming potentials. Source: Ramboll Environ US Corporation, May 2015.

C. Regulatory Framework

Climate change and GHG emissions are governed by an evolving body of laws, regulations, and case law. Below are summaries of some of the key regulations; however, the discussion below should not be considered exhaustive of this growing body of regulation.

i ) Federal

1) Supreme Court Ruling in Massachusetts et al. v. Environmental Protection Agency

The George W. Bush Administration’s approach to addressing climate change was challenged in Massachusetts et al. v. Environmental Protection Agency (EPA), 549 US 497 (2007). In this decision, the U.S. Supreme Court held that the United States Environmental Protection Agency (USEPA) was authorized by the Clean Air Act to regulate CO2 emissions from new motor vehicles.4 The Court did not mandate that the USEPA enact regulations to reduce GHG emissions, but found that the only instances in which the USEPA could avoid taking action were if it found that GHGs do not contribute to climate change or if it offered a “reasonable explanation” for not determining that GHGs contribute to climate change.

On December 7, 2009, the USEPA issued an “endangerment finding” under the Clean Air Act, concluding that GHGs threaten the public health and welfare of current and future generations and that motor vehicles contribute to greenhouse gas pollution.5 These findings provide the basis for adopting new

4 Massachusetts, et al. v. Environmental Protection Agency (2007), website: http://www.law.cornell.edu/supct/html/05-‐1120.ZS.html, accessed: November 2014.

5 United States Environmental Protection Agency, Endangerment, and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act, website: http://www.epa.gov/climatechange/endangerment/, accessed: November 2014.



national regulations to mandate GHG emission reductions under the federal Clean Air Act. The EPA’s endangerment finding paves the way for federal regulation of GHGs.

Under the Consolidated Appropriations Act of 2008 (HR 2764), Congress has established mandatory GHG reporting requirements for some emitters of GHGs. In addition, on September 22, 2009, the EPA issued the Final Mandatory Reporting of Greenhouse Gases Rule. The rule requires annual reporting to the EPA of GHG emissions from large sources and suppliers of GHGs, including facilities that emit 25,000 metric tons (MT) or more a year of GHGs.

2) United States Environmental Protection Agency and National Highway Traffic Safety Administration Joint Rulemaking for Vehicle Standards

In response to the Massachusetts v. EPA ruling discussed above, the Bush Administration issued an Executive Order on May 14, 2007, directing the USEPA, the Department of Transportation (DOT), and the Department of Energy to establish regulations that reduce GHG emissions from motor vehicles, non-‐road vehicles, and non-‐road engines by 2008.

On October 10, 2008, the National Highway Traffic Safety Administration (NHTSA) released a final environmental impact statement analyzing proposed interim standards for passenger cars and light trucks in model years 2011 through 2015. The NHTSA issued a final rule for model year 2011 on March 30, 2009.6

On May 7, 2010, the USEPA and the NHTSA issued a final rule regulating fuel efficiency and GHG pollution from motor vehicles for cars and light-‐duty trucks for model years 2012–2016.7 On May 21, 2010, President Barack Obama issued a memorandum to the Secretaries of Transportation and Energy, and the Administrators of the USEPA and the NHTSA calling for establishment of additional standards regarding fuel efficiency and GHG reduction, clean fuels, and advanced vehicle infrastructure.8 In response to this directive, USEPA and NHTSA issued a Supplemental Notice of Intent announcing plans to propose stringent, coordinated federal greenhouse gas and fuel economy standards for model year 2017-‐2025 light-‐duty vehicles.9 The agencies proposed standards projected to achieve 163 grams/mile of CO2 in model year 2025, on an average industry fleet wide basis, which is equivalent to 54.5 miles per gallon if this level were achieved solely through fuel efficiency. California has announced its support of

6 National Highway Traffic Safety Administration, Laws & Regulations, CARE -‐ Fuel Economy, Average Fuel

Economy Standards Passenger Cars and Light Trucks Model Year 2011, Final Rule, March 23, 2009, website: http://www.nhtsa.gov/DOT/NHTSA/Rulemaking/Rules/Associated%20Files/CAFE_Updated_Final_Rule_MY2011.pdf, accessed: November 2014.

7 United States Environmental Protection Agency, Light Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Final Rule, May 7, 2010, website: https://www.federalregister.gov/articles/2010/05/07/2010-‐8159/light-‐duty-‐vehicle-‐greenhouse-‐gas-‐emission-‐standards-‐and-‐corporate-‐average-‐fuel-‐economy-‐standards, accessed: November 2014.

8 Government Printing Office, Federal Register, Vol. 75, No. 101, Presidential Documents, Improving Energy Security, American Competitiveness and Job Creation, and Environmental Protection Through a Transformation of Our Nation's Fleet of Cars and Trucks, May 21, 2010, website: http://www.gpo.gov/fdsys/pkg/FR-‐2010-‐05-‐26/html/2010-‐12757.htm, accessed: November 2014.

9 Government Printing Office, Federal Register, Vol. 76, No. 153, Proposed Rules, 2017-‐2025 Model Year Light-‐Duty Vehicle GHG Emissions and CAFÉ Standards: Supplemental Notice of Intent, August 9, 2011, website: http://gpo.gov/fdsys/pkg/FR-‐2011-‐08-‐09/pdf/2011-‐19905.pdf, accessed: November 2014.



this national program.10 The final rule was adopted in October 2012, and NHSTA intends to set standards for model years 2022-‐2025 in a future rulemaking.11, 12.

3) Heavy-‐duty Engines and Vehicles Fuel Efficiency Standards

In addition to the regulations applicable to cars and light-‐duty trucks, on August 9, 2011, the USEPA and the NHTSA announced fuel economy and GHG standards for medium-‐ and heavy-‐duty trucks, which applies to vehicles from model years 2014 through 2018.13 The

USEPA and the NHTSA have adopted standards for CO2 emissions and fuel consumption, respectively, tailored to each of three main vehicle categories: combination tractors, heavy-‐duty pickup trucks and vans, and vocational vehicles. According to USEPA, this program will reduce GHG emissions and fuel consumption for affected vehicles by 6 percent to 23 percent.

4) Energy Independence and Security Act

On December 19, 2007, the Energy Independence and Security Act of 2007 (EISA) was signed into law.14 Among other key measures, the EISA would do the following, which would aid in the reduction of national GHG emissions, both mobile and non-‐mobile:

1. Increase the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring fuel producers to use at least 36 billion gallons of biofuel in 2022.

2. Prescribe or revise standards affecting regional efficiency for heating and cooling products, procedures for new or amended standards, energy conservation, energy efficiency labelling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances.

3. While superseded by NHTSA and USEPA actions described above, EISA also set miles per gallon targets for cars and light trucks and directed the NHTSA to establish a fuel economy program for medium-‐ and heavy-‐duty trucks and create a separate fuel economy standard for work trucks.

10 California Air Resource Board, Commitment Letter to National Program, July 28, 2011, website:

http://www.epa.gov/otaq/climate/letters/carb-‐commitment-‐ltr.pdf, accessed: November 2014. 11 National Highway Traffic Safety Administration, Federal Register, Vol. 77, No. 199, Rules & Regulations, 2017

and Later Model Year Light-‐Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards, effective December 14, 2012, website: https://federalregister.gov/a/2012-‐21972, accessed: November 2014.

12 National Highway Traffic Safety Administration, Corporate Average Fuel Economy Standards, Passenger Cars and Light Trucks, Model Years 2017-‐2025, Final Environmental Impact Statement, July 2012, website: http://www.nhtsa.gov/staticfiles/rulemaking/pdf/cafe/FINAL_EIS.pdf. Accessed: November, 2014.

13 United States Environmental Protection Agency, Office of Transportation and Air Quality. EPA and NHTSA Adopt First-‐Ever Program to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium-‐and Heavy-‐Duty Vehicles, August 2011, website: http://www.epa.gov/otaq/climate/documents/420f11031.pdf, accessed: November 2014.

14 Government Printing Office, Energy Independence and Security Act of 2007, January 4, 2007, website: http://www.gpo.gov/fdsys/pkg/BILLS-‐110hr6enr/pdf/BILLS-‐110hr6enr.pdf, accessed: November, 2014.



Additional provisions of the EISA address energy savings in government and public institutions, promoting research for alternative energy, additional research in carbon capture, international energy programs, and the creation of “green jobs.”

i i ) State

1) Assembly Bill 32 (Statewide GHG Reductions)

The California Global Warming Solutions Act of 2006 (AB 32) was signed into law in September 2006 after considerable study and expert testimony before the Legislature. The law instructs the California Air Resources Board (CARB) to develop and enforce regulations for the reporting and verifying of statewide GHG emissions. The Act directed CARB to set a GHG emission limit based on 1990 levels, to be achieved by 2020. The bill set a timeline for adopting a scoping plan for achieving GHG reductions in a technologically and economically feasible manner.15

The heart of the bill is the requirement that statewide GHG emissions be reduced to 1990 levels by 2020. The bill required CARB to adopt rules and regulations in an open public process to achieve the maximum technologically feasible and cost-‐effective GHG reductions. CARB accomplished the key milestones set forth in AB 32 including the following:

• June 30, 2007. Identification of discrete early action GHG emissions reduction measures. On June 21, 2007, CARB satisfied this requirement by approving three early action measures.16 These were later supplemented by adding six other discrete early action measures.17

• January 1, 2008. Identification of the 1990 baseline GHG emissions level and approval of a statewide limit equivalent to that level and adoption of reporting and verification requirements concerning GHG emissions. On December 6, 2007, CARB approved a statewide limit on GHG emissions levels for the year 2020 consistent with the determined 1990 baseline.18

• January 1, 2009. Adoption of a scoping plan for achieving GHG emission reductions. On December 11, 2008, CARB adopted Climate Change Scoping Plan: A Framework for Change (Scoping Plan), discussed in more detail below.19

15 Legislative Counsel of California, California Assembly Bill 32, September 2006, website:

http://www.leginfo.ca.gov/pub/05-‐06/bill/asm/ab_0001-‐0050/ab_32_bill_20060927_chaptered.pdf, accessed: November 2014.

16 California Air Resources Board, Summary of Board Meeting, Consideration of Recommendations for Discrete Early Actions for Climate Change Mitigation in California, June 21-‐22, 2007, website: http://www.arb.ca.gov/board/ms/2007/ms062107.pdf, accessed: November 2014.

17 California Air Resources Board, Summary of Board Meeting, Public Meeting to Consider Approval of Additions to Reduce Greenhouse Gas Emissions under the California Global Warming Solutions Act of 2006 and to Discuss Concepts for Promoting and Recognizing Voluntary Early Actions, October 25-‐26, 2007, website: http://www.arb.ca.gov/board/ms/2007/ms102507.pdf, accessed: November, 2014.

18 California Air Resources Board, Staff Report, California 1990 Greenhouse Gas Emissions Level and 2020 Emissions Limit, November 16, 2007, website: http://www.arb.ca.gov/cc/inventory/pubs/reports/staff_report_1990_level.pdf, accessed: November 2014.

19 California Air Resources Board, Climate Change Scoping Plan, December 2008, website: http://www.arb.ca.gov/cc/scopingplan/document/adopted_scoping_plan.pdf, accessed: November 2014.



• January 1, 2010. Adoption and enforcement of regulations to implement the “discrete” actions. Several early action measures have been adopted and became effective on January 1, 2010.20, 21

• January 1, 2011. Adoption of GHG emissions limits and reduction measures by regulation. On October 28, 2010, CARB released its proposed cap-‐and-‐trade regulations, which would cover sources of approximately 85 percent of California's GHG emissions.22 CARB’s Board ordered its Executive Director to prepare a final regulatory package for cap-‐and-‐trade on December 16, 2010.23

• January 1, 2012. GHG emissions limits and reduction measures adopted in 2011 became enforceable.

As noted above, on December 11, 2008, CARB adopted the Scoping Plan to achieve the goals of AB 32. The Scoping Plan establishes an overall framework for the measures that will be adopted to reduce California’s GHG emissions for various categories of emissions. CARB determined that achieving the 1990 emission level by 2020 would require an approximately 28.5 percent reduction of GHG emissions in the absence of new laws and regulations (referred to as “business as usual” or “No Action Taken” [NAT]). The Scoping Plan evaluates opportunities for sector-‐specific reductions, integrates all CARB and Climate Action Team early actions and additional GHG reduction measures by both entities, and identifies additional measures to be pursued as regulations, and outlines the role of a cap-‐and-‐trade program. The key elements of the Scoping Plan include the following:24

• Expanding and strengthening existing energy efficiency programs as well as building and appliance standards;

• Achieving a statewide renewable energy mix of 33 percent;

• Developing a California cap-‐and-‐trade program that links with other Western Climate Initiative partner programs to create a regional market system and caps sources contributing 85 percent of California's GHG emissions;

• Establishing targets for transportation-‐related GHG emissions for regions throughout California, and pursuing policies and incentives to achieve those targets;

20 California Air Resources Board, Summary of Board Meeting, Consideration of Recommendations for Discrete

Early Actions for Climate Change Mitigation in California, June 21-‐22, 2007, website: http://www.arb.ca.gov/board/ms/2007/ms062107.pdf, accessed: November 2014.

21 California Air Resources Board, Summary of Board Meeting, Public Meeting to Consider Approval of Additions to Reduce Greenhouse Gas Emissions under the California Global Warming Solutions Act of 2006 and to Discuss Concepts for Promoting and Recognizing Voluntary Early Actions, October 25-‐26, 2007, website: http://www.arb.ca.gov/board/ms/2007/ms102507.pdf, accessed: November 2014.

22 California Air Resources Board, Proposed Regulation to Implement the California Cap-‐and-‐Trade Program, December 16, 2010, website: http://www.arb.ca.gov/regact/2010/capandtrade10/capandtrade10.htm, accessed: November 2014.

23 California Air Resources Board, California Cap-‐and-‐Trade Program, Resolution 10-‐42, December 16, 2010, website: http://www.arb.ca.gov/regact/2010/capandtrade10/res1042.pdf, accessed: November 2014.




• Adopting and implementing measures pursuant to existing state laws and policies, including California's clean car standards, goods movement measures, and the Low Carbon Fuel Standard; and

• Creating targeted fees, including a public goods charge on water use, fees on high global warming potential gases, and a fee to fund the administrative costs of the State of California's long-‐term commitment to AB 32 implementation.

In connection with preparation of the supplement to the Functional Equivalent Document, CARB released revised estimates of the expected 2020 emission reductions in consideration of the economic recession and the availability of updated information from development of measure-‐specific regulations. Incorporation of revised estimates in consideration of the economic recession reduced the projected 2020 emissions from 596 metric tonnes of CO2 equivalent (MTCO2e) to 545 million MTCO2e (MMTCO2e).25 Under this scenario, achieving the 1990 emissions level would require a reduction of GHG emissions of 118 MMTCO2e, or 21.7 percent, to achieve in 2020 emissions levels in the “business as usual” condition. This revised reduction represents a 6.8 percentage point reduction from the 28.5 percent level determined in CARB’s 2008 Scoping Plan. The 2020 AB 32 baseline was also updated to account for measures incorporated into the inventory, including Pavley (vehicle model-‐years 2009 -‐ 2016) and the renewable portfolio standard (12% -‐ 20%). Inclusion of these measures further reduced the 2020 baseline to 507 MMTCO2e. As a result, based on both the economic recession and the availability of updated information from development of measure-‐specific regulations, achieving the 1990 emission level would now require a reduction of GHG emissions of 80 MMTCO2e or a reduction by approximately 16 percent (down from the 28.5 percent level determined in CARB’s 2008 Scoping Plan) by 2020 in the “business as usual” or NAT condition.26,27

On October 1, 2013, CARB released a discussion draft first update to the Scoping Plan. The discussion draft recalculates 1990 GHG emissions using Intergovernmental Panel on Climate Change (IPCC) Fourth Assessment Report released in 2007. Using the AR4 global warming potentials (GWPs), the 427 MMTCO2e 1990 emissions level and 2020 GHG emissions limit would be slightly higher, at 431 MMTCO2e.28 Based on the revised estimates of expected 2020 emissions identified in the 2011 supplement to the Functional Environmental Document and updated 1990 emissions levels identified in the draft first update to the Scoping Plan, achieving the 1990 emission level would require a reduction of 76 MMTCO2e (down from 507 MMTCO2e) or a reduction by approximately 15

25 California Air Resources Board, Status of Scoping Plan Recommended Measures, July 25, 2011, website:

http://www.arb.ca.gov/cc/scopingplan/status_of_scoping_plan_measures.pdf, accessed: November 2014. 26 California Air Resources Board, Status of Scoping Plan Recommended Measures, July 25, 2011, website:

http://www.arb.ca.gov/cc/scopingplan/status_of_scoping_plan_measures.pdf, accessed: November 2014. 27 California Air Resources Board, Final Supplement to the AB 32 Scoping Plan Functional Equivalent Document,

website: http://www.arb.ca.gov/cc/scopingplan/document/final_supplement_to_sp_fed.pdf, accessed: December 2014.

28 California Air Resources Board, Climate Change Scoping Plan First Update, Discussion Draft for Public Review and Comment, October 2013, website: http://www.arb.ca.gov/cc/scopingplan/2013_update/discussion_draft.pdf, accessed: November 2014.

Global warming potentials (GWPs) are one type of simplified index based upon radiative properties that can be used to estimate the potential future impacts of emissions of different gases upon the climate system, in a relative sense.



percent (down from 28.5 percent) to achieve in 2020 emissions levels in the “business as usual” or NAT condition.29, 30, 31

However, it should be noted that in a recent California Supreme Court decision (Center for Biological Diversity v California Department of Fish and Wildlife), the court held that a significance criterion framed in terms of efficiency is superior to a simple numerical threshold because long-‐term growth in California’s population and economic activity will occur in different ways throughout the State and will inevitably result in increased GHG emissions. CEQA is not intended as a population or economic control measure. Meeting Statewide reduction goals does not preclude all new development, but rather, the Scoping Plan assumes continued growth and depends on increased efficiency and conservation in land use and transportation from all Californians. The Scoping Plan does not relate the Statewide level of reduction effort to the percentage of reduction that would or should be required from individual projects. Thus, a project-‐level reduction that meets or exceeds the Scoping Plan’s quantified percentage reduction goal does not in and of itself demonstrate consistency with AB 32. For example, as noted above, a 15 percent Statewide reduction of GHG emissions from the “business as usual” or NAT condition is required to achieve 1990 levels by 2020; however, this reduction percentage is not intended to be a quantified impact threshold at the project level and, therefore, should not be misinterpreted to mean projects must achieve a minimum of 15 percent reduction from “business as usual” or NAT conditions in order for a project’s specific or cumulative impacts to be less than significant.

A “business as usual” comparison as a sole criterion of significance does not substantiate whether a significant impact would result. However, should a lead agency choose to rely on a quantified threshold of significance, albeit not required, CEQA demands the agency research and document the quantitative parameters essential to that method. It should be noted that the City has not developed a quantified threshold of significance for GHG emissions. The primary threshold of significance is based, instead, on qualitative consistency with GHG reduction plans, policies, and performance standards. A quantification of existing and projected GHG emissions by the Project is nonetheless still required under CEQA.

2) Renewable Portfolio Standards (SB 1078, SB 107, and SBX1-‐2)

Established in 2002 under Senate Bill (SB) 1078, and accelerated in 2006 under SB 107 and again in 2011 under SBX1-‐2, California’s Renewable Portfolio Standards (RPS) requires retail sellers of electric services to increase procurement from eligible renewable energy resources to 33 percent of total retail sales by 2020.32,33,34 The 33 percent standard is consistent with the RPS goal established in the Scoping Plan.35 29 California Air Resources Board, Status of Scoping Plan Recommended Measures, July 25, 2011, website:

http://www.arb.ca.gov/cc/scopingplan/status_of_scoping_plan_measures.pdf, accessed: December 2014. 30 California Air Resources Board, Final Supplement to the AB 32 Scoping Plan Functional Equivalent

Document, website: http://www.arb.ca.gov/cc/scopingplan/document/final_supplement_to_sp_fed.pdf, accessed: November 2014.

31 California Air Resources Board, Climate Change Scoping Plan First Update, Discussion Draft for Public Review and Comment, October 2013, website: http://www.arb.ca.gov/cc/scopingplan/2013_update/discussion_draft.pdf, accessed: November, 2014

32 Legislative Counsel of California, Senate Bill 1078, September 2002, website: http://www.energy.ca.gov/portfolio/documents/documents/SB1078.PDF, accessed: November 2014.

33 Legislative Counsel of California, Senate Bill 1368, September 2006, website: http://www.energy.ca.gov/emission_standards/documents/sb_1368_bill_20060929_chaptered.pdf. accessed: November 2014.



As interim measures, the RPS requires 20 percent of retail sales to be sourced from renewable energy by 2013, and 25 percent by 2016. Initially, the RPS provisions applied to investor-‐owned utilities, community choice aggregators, and electric service providers. SBX1-‐2 added, for the first time, publicly-‐owned utilities to the entities subject to RPS.36 The expected growth in RPS to meet the standards in effect in 2008 is not reflected in the “business as usual” calculation in the AB 32 Scoping Plan, discussed below. In other words, the Scoping Plan’s “business as usual” 2020 does not take credit for implementation of RPS that occurred after its adoption.37

3) GHG Emissions Standard for Baseload Generation (SB 1368)

Senate Bill 1368 (SB 1368), which was signed into law on September 29, 2006, prohibits any retail seller of electricity in California from entering into a long-‐term financial commitment for baseload generation if the GHG emissions are higher than those from a combined-‐cycle natural gas power plant. This performance standard (i.e., reducing long-‐term GHG emissions as a result of electrical baseload generation) applies to electricity generated both within and outside of California, and to publicly owned as well as investor-‐owned electric utilities.

4) Mobile Source Reductions (AB 1493)

Assembly Bill 1493, the “Pavley Standard”, required CARB to adopt regulations by January 1, 2005, to reduce GHG emissions from non-‐commercial passenger vehicles and light-‐duty trucks of model year 2009 through 2016. The bill also required the California

Climate Action Registry to develop and adopt protocols for the reporting and certification of GHG emissions reductions from mobile sources for use by CARB in granting emission reduction credits. The bill authorizes CARB to grant emission reduction credits for reductions of GHG emissions prior to the date of enforcement of regulations, using model year 2000 as the baseline for reduction.

In 2004, CARB applied to the USEPA for a waiver under the federal Clean Air Act to authorize implementation of these regulations. The waiver request was formally denied by the USEPA in December 2007 after California filed suit to prompt federal action. In January 2008, the State Attorney General filed a new lawsuit against the USEPA for denying California's request for a waiver to regulate and limit GHG emissions from these vehicles. In January 2009, President Barack Obama issued a

34 California Air Resources Board, et al., v. Association of Irritated Residents, et al., (2011), website:

http://www.crpe-‐ej.org/crpe/images/stories/7.25.11_Petition_for_Review_FINAL_with_Exhibits_smaller_version.pdf, accessed: November 2014.


36 California Air Resources Board, et al., v. Association of Irritated Residents, et al., 2011, website: http://www.crpe-‐j.org/crpe/images/stories/7.25.11_Petition_for_Review_FINAL_with_Exhibits_smaller_version.pdf, accessed: November 2014.

37 California Air Resources Board, Climate Change Scoping Plan Appendices, Vol. I, December 2008, website: http://www.arb.ca.gov/cc/scopingplan/document/appendices_volume1.pdf, accessed: November 2014.

Baseload is the minimum amount of power an electrical, or other utility, company must generate in a 24-‐hour time period to meet estimated demand from its customers.



directive to the USEPA to reconsider California’s request for a waiver. On June 30, 2009, the USEPA granted the waiver to California for its GHG emission standards for motor vehicles. As part of this waiver, USEPA specified the following provision: CARB may not hold a manufacturer liable or responsible for any noncompliance caused by emission debits generated by a manufacturer for the 2009 model year. CARB has adopted a new approach to passenger vehicles (cars and light trucks), by combining the control of smog-‐causing pollutants and GHG emissions into a single coordinated package of standards. The new approach also includes efforts to support and accelerate the numbers of plug-‐in hybrids and zero-‐emission vehicles in California. These standards will apply to all passenger and light duty trucks used by customers, employees of, and deliveries to the Project.

5) Low Carbon Fuel Standard

Executive Order S-‐01-‐07 (January 18, 2007) requires a 10 percent or greater reduction in the average fuel carbon intensity for transportation fuels in California regulated by CARB. CARB identified the Low Carbon Fuel Standard (LCFS) as a Discrete Early Action item under AB 32, and the final resolution (09-‐31) was issued on April 23, 2009.38 In 2009, CARB approved for adoption the LCFS regulation, which became fully effective in April 2010 and is codified at Title 17, CCR, Sections 95480-‐95490. The LCFS will reduce GHG emissions by reducing the carbon intensity of transportation fuels used in California by at least 10 percent by 2020. Carbon intensity is a measure of the GHG emissions associated with the various production, distribution, and use steps in the “lifecycle” of a transportation fuel. On December 29, 2011, the U.S. District Court for the Eastern District of California issued several rulings in the federal lawsuits challenging the LCFS. One of the district court’s rulings preliminarily enjoined the CARB from enforcing the regulation. In January 2012, CARB appealed that decision to the Ninth Circuit Court of Appeals. On September 18, 2013, the Ninth Circuit issued its decision affirming the District Court's conclusion that LCFS ethanol and initial crude-‐oil provisions are not facially discriminatory, but returned the case to the U.S. District Court for the Eastern District of California to determine whether the LCFS ethanol provisions are discriminatory in purpose and effect. Additionally, the Ninth Circuit returned the case to U.S. District Court with instructions to remove the preliminary injunction against CARB’s enforcement of the regulation.

6) Senate Bill 97

Per Senate Bill 97, which was signed into law on August 24, 2007, the California Natural Resources Agency adopted amendments to the CEQA Guidelines, which address the specific obligations of public agencies when analyzing GHG emissions under CEQA to determine a project’s effects on the environment (codified as Public Resources Code 21083.05). Specifically, Public Resources Code 21083.05 states, “The Office of Planning and Research and the Natural Resources Agency shall periodically update the guidelines for the mitigation of greenhouse gas emissions or the effects of greenhouse gas emissions.”

38 California Air Resources Board, Initial Statement of Reason for Proposed Regulation for The Management of

High Global Warming Potential Refrigerant for Stationary Sources, October 23, 2009, website: http://www.arb.ca.gov/regact/2009/gwprmp09/isorref.pdf, accessed: November 2014.



7) Senate Bill 375

In September 2008, the California legislature adopted SB 375, legislation which: (1) relaxes CEQA requirements for some housing projects that meet goals for reducing GHG emissions; and (2) requires the regional governing bodies in each of the state’s major metropolitan areas to adopt, as part of their regional transportation plan, “sustainable community strategies” that will meet the region’s target for reducing GHG emissions. SB 375 creates incentives for implementing the sustainable community strategies by allocating federal transportation funds only to projects that are consistent with the emissions reductions.

Local governments would then devise strategies for housing development, road-‐building and other land uses to shorten travel distances, reduce vehicular travel time and meet the new targets. If regions develop these integrated land use, housing, and transportation plans, residential projects that conform to the sustainable community strategy (and therefore contribute to GHG reduction) can have a more streamlined environmental review process.

8) Clean Cars

In January 2012, CARB approved the Advanced Clean Cars Program, a new emissions-‐control program for model year 2017 through 2025. The program combines the control of smog, soot, and GHGs with requirements for greater numbers of zero-‐emission vehicles. By 2025, when the rules will be fully implemented, the new automobiles will emit 34 percent fewer global warming gases and 75 percent fewer smog-‐forming emissions.

9) Green Building Code (California Code of Regulations, Title 24)

Although not originally intended to reduce greenhouse gas emissions, California Code of Regulations (CCR) Title 24 Part 6: California’s Energy Efficiency Standards for Residential and Nonresidential Buildings, was first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption. Since then, Title 24 has been amended to recognize that energy-‐efficient buildings require less electricity and reduce fuel consumption, which, in-‐turn, decreases GHG emissions. The current 2013 Title 24

standards were adopted to respond, among other reasons, to the requirements of AB 32. Specifically, new development projects constructed within California after January 1, 2014 are subject to the mandatory planning and design, energy efficiency, water efficiency and conservation, material conservation and resources efficiency, and environmental quality measures of the California Green Building Standards (CALGreen) Code (California Code of Regulations, Title 24, Part 11). The outdoor water use standards of the CALGreen Code are already addressed by the City’s Water Conservation Ordinance.

10) Executive Order B-‐30-‐15

On April 29, 1015, Governor Edmund G. Brown Jr. issued an executive order to establish a California greenhouse gas reduction target of 40 percent below 1990 levels by 2030. This new emission reduction target of 40 percent below 1990 levels by 2030 is a step toward the ultimate goal of reducing emissions by 80 percent below 1990 levels by 2050. The executive order also specifically addresses the need for climate adaptation and directs state government to:

• Incorporate climate change impacts into the state’s Five-‐Year Infrastructure Plan;



• Update the Safeguarding California Plan -‐ the state climate adaption strategy -‐ to identify how climate change will affect California infrastructure and industry and what actions the state can take to reduce the risks posed by climate change;

• Factor climate change into state agencies' planning and investment decisions; and

• Implement measures under existing agency and departmental authority to reduce greenhouse gas emissions.

11) Cap-‐and-‐Trade Program

As mentioned above, the Scoping Plan identifies a cap-‐and-‐trade program as one of the strategies the State will employ to reduce GHG emissions that cause climate change. The cap-‐and-‐trade program is implemented by CARB and “caps” GHG emissions from the industrial, utility, and transportation fuels sections, which account for roughly 85 percent of the State’s GHG emissions. The program works by establishing a hard cap on about 85 percent of total Statewide GHG emissions. The cap starts at expected business-‐as-‐usual emissions levels in 2012, and declines two to three percent per year through 2020. Fewer and fewer GHG emissions allowances are available each year, requiring covered sources to reduce their emissions or pay increasingly higher prices for those allowances. The cap level is set in 2020 to ensure California complies with AB 32’s emission reduction target of returning to 1990 GHG emission levels.

The scope of GHG emission sources subject to cap-‐and-‐trade in the first compliance period (2013-‐2014) includes all electricity generated and imported into California (the first deliverer of electricity into the State in the “capped” entity and that one that will have to purchase allowances as appropriate), and large industrial facilities emitting more than 25,000 MTCO2E per year (e.g., oil refineries and cement manufacturers). The scope of GHG emission sources subjected to cap-‐and-‐trade during the second compliance period (2015-‐2017) expands to include distributors of transportation fuels (including gasoline and diesel), natural gas, and other fuels. The regulated entity will be the fuel provider that distributes the fuel upstream (not the gas station). In total, the cap-‐and-‐trade program is expected to include roughly 350 large businesses, representing about 600 facilities. Individuals and small businesses will not be regulated.

Under the program, companies do not have individual or facility-‐specific reduction requirements. Rather, all companies covered by the regulation are required to turn in allowances in an amount equal to their total GHG emissions during each phase of the program. The program gives companies the flexibility to either trade allowances with others or take steps to cost-‐effectively reduce emissions at their own facilities. Companies that emit more will have to turn in more allowances. Companies that can cut their emissions will have to turn in fewer allowances. Furthermore, as the cap declines, total GHG emissions are reduced. On October 20, 2011, CARB’s Board adopted the final cap-‐and-‐trade regulation. The cap-‐and-‐trade program began on January 1, 2012, with an enforceable compliance obligation beginning with the 2013 GHG emissions.

i i i ) Regional and Local

1) South Coast Air Quality Management District Policies (SCAQMD)

SCAQMD is principally responsible for comprehensive air pollution control in the Basin, which includes Los Angeles, Orange, and the urbanized portions of Riverside and San Bernardino Counties, including the Project Site. SCAQMD works directly with Southern California Association of Governments, County



transportation commissions, and local governments and cooperates actively with all federal and State government agencies to regulate air quality.

2) City of Los Angeles Policies and Regulations

The City adopted the pertinent provisions of the 2013 CALGreen standards through Ordinance No. 182,849, adopted December 17, 2013.

Prior to this and the adoption of previous Green Building Ordinances, the City began to address the issue of global climate change by publishing Green LA, An Action Plan to Lead the Nation in Fighting Global Warming (LA Green Plan). This document outlines the goals and actions the City has established to reduce the generation and emission of GHGs from both public and private activities. According to the LA Green Plan, the City is committed to the goal of reducing emissions of CO2 to 35 percent below 1990 levels. To achieve this, the City will:

• Increase the generation of renewable energy;

• Improve energy conservation and efficiency; and

• Change transportation and land use patterns to reduce dependence on automobiles.

In December 2013, the Los Angeles City Council adopted various provisions of the CALGreen Code as part of Ordinance No. 182,849, thus codifying certain provisions of the 2013 CALGreen Code as the new Los Angeles Green Building Code (LA Green Building Code). The LA Green Building Code imposes more stringent green building requirements than those contained within the CALGreen Code, and is applicable to the construction of every new building, every new building alteration with a permit valuation of over $200,000, and every building addition unless otherwise noted. Specific mandatory requirements and elective measures are provided for three categories:

(1) Low-‐rise residential buildings;

(2) Nonresidential and high-‐rise residential buildings; and

(3) Additions and alterations to nonresidential and high-‐rise residential buildings.

3. ENVIRONMENTAL IMPACTS

A. Methodology

As discussed under “Assembly Bill 32” and “Renewable Portfolio Standards”, the “business as usual” condition does not take credit for implementation of the RPS that occurred after its adoption. Therefore, the “business as usual” calculation of greenhouse gas emissions does not represent the most conservative approach to the analysis of environmental impacts. The methodology discussed below is generally accepted as a more conservative approach to calculate greenhouse gas emissions.



i ) CalEEMod™

This analysis primarily used the California Emission Estimator Model version 2013.2.2 (CalEEMod™)39 to assist in quantifying the GHG emissions in the inventories presented in this report for the Project. CalEEMod™ is a statewide program designed to calculate both criteria and GHG emissions from development projects in California. This model was developed under the auspices of the SCAQMD and received input from other California air districts, and is currently supported by several lead agencies for use in quantifying the emissions associated with development projects undergoing environmental review. CalEEMod™ uses widely accepted models for emission estimates combined with appropriate default data that can be used if site-‐specific information is not available. These models and default estimates use sources such as the USEPA AP-‐42 emission factors,40 CARB’s on-‐road and off-‐road equipment emission models such as the EMission FACtor model (EMFAC) and the Emissions Inventory Program model (OFFROAD), and studies commissioned by California agencies such as the California Energy Commission and CalRecycle.

CalEEMod™ is based upon the Air Resources Board (ARB)-‐approved Off-‐Road and On-‐Road Mobile-‐Source Emission Factor models (OFFROAD and EMFAC, respectively), and is designed to estimate construction and operational emissions for land use development projects and allows for the input of project specific information. OFFROAD41 is an emissions factor model used to calculate emission rates from off-‐road mobile sources (e.g., construction equipment, agricultural equipment). EMFAC42 is an emissions factor model used to calculate emissions rates from on-‐road vehicles (e.g., passenger vehicles, haul trucks). The off-‐road diesel emission factors used by CalEEMod™ are based on the ARB OFFROAD2011 program.

CalEEModTM provides a simple platform to calculate both construction emissions and operational emissions from a land use project. It calculates both the daily maximum and annual average for criteria pollutants as well as total or annual GHG emissions. The model also provides default values for water and energy use. Specifically the model aids the user in the following calculations:

• Short-‐term construction emissions associated with demolition, site preparation, grading, building, coating, and paving from off-‐road construction equipment, on-‐road mobile equipment associated with workers, vendors, and hauling, and fugitive dust associated with grading, demolition, truck loading, and roads, and volatile emissions of reactive organic gasses (ROG) from architectural coating and paving. Fugitive dust from windblown sources, such as storage piles is not quantified in CalEEModTM, which is consistent with approaches taken in other comprehensive models.

39 South Coast Air Quality Management District, 2013, California Emissions Estimator Model, website:

http://www.CalEEMod.com/, accessed: December 2014. 40 The USEPA maintains a compilation of Air Pollutant Emission Factors and process information for several air

pollution source categories. The data is based on source test data, material balance studies, and engineering estimates, website: http://epa.gov/ttnchie1/ap42/, accessed: November 2014.

41 California Air Resources Board, 2011. Off Road Mobile Source Emission factors, website: http://www.arb.ca.gov/msei/msei.htm, accessed: November 2014.

42 California Air Resources Board, 2013, Mobile Source Emission Inventory -‐-‐ Current Methods and Data, website: http://www.arb.ca.gov/msei/modeling.htm, accessed: November 2014.



• Operational emissions are associated with the fully built out land use development, such as on-‐road mobile vehicle traffic, fugitive dust from roads, volatile emissions of ROG from architectural coating, off-‐road emissions from landscaping equipment, volatile emissions of ROG from consumer products and cleaning supplies, natural gas use, electricity use, water use, and solid waste disposal.

• One-‐time vegetation sequestration changes, such as permanent vegetation land use changes and new tree plantings.

Mitigation impacts to both short-‐term construction and operational emissions as described in California Air Pollution Control Officers Association’s (CAPCOA) Quantifying Greenhouse Gas Mitigation Measures.43 In addition, CalEEModTM contains default values and existing regulation methodologies to use in each specific local air district region. Appropriate statewide default values can be used if regional default values are not defined. This analysis used default factors for Los Angeles – South Coast County area that is within the SCAQMD jurisdiction for the GHG emission inventory, unless otherwise noted in the methodology descriptions below.

This analysis directly or indirectly relied on emissions estimation guidance from government-‐sponsored organizations, government-‐commissioned studies of energy use patterns, energy surveys by other consulting firms, project-‐specific studies (e.g., Transportation Analysis Report, lighting energy for parking structure), and emission estimation software as described above. In cases as noted below, third-‐party studies were also relied upon to support analyses and assumptions made outside of the approach described above.

i i ) Indirect Greenhouse Gas Emissions from Electricity Use

The indirect GHG emissions created as a result of electricity use are based on the following methodology. Indirect emissions, such as when electricity is used in a building, are typically due to electricity generation from offsite power plant locations. For the Project, electrical power would be supplied by the Los Angeles Department of Water and Power (LADWP).

Using CalEEModTM, the electricity intensities are multiplied by emission intensity factors for the GHGs and are classified as indirect emissions. For this Project, the CalEEMod CO2 intensity factor is modified based on the average factor from 2006 and 2007 to account for the RPS. The intensity factors for total energy delivered were estimated by multiplying the percentage of energy delivered from non-‐renewable energy by the CO2 emissions per total non-‐renewable energy metric calculated. Total energy delivery and total CO2 emissions are provided in LADWP/Utility Protocol Reports. The CO2 intensity factor presented in this analysis is consistent with the 33 percent RPS for 2020. The estimate provided here and the Utility Protocol Reports issued by LADWP assume that renewable energy sources do not result in any CO2 emissions. CalEEModTM emission intensity factors for CH4 and N2O were used for this Project as a conservative estimate for these emissions.

43 California Air Pollution Control Officers Association, Quantifying Greenhouse Gas Mitigation Measures, August

2010, website: http://www.capcoa.org/wp-‐content/uploads/2010/11/CAPCOA-‐Quantification-‐Report-‐9-‐14-‐Final.pdf, accessed: May 26, 2015.

Carbon sequestration is the process of capture and long-‐term storage of atmospheric CO2.



Details regarding the specific methodologies used by CalEEMod™ can be found in the CalEEMod™ User’s Guide and associated appendices.44 The CalEEMod™ output files are provided for reference in Appendix A to the Greenhouse Gas Technical Report (Appendix G to this Draft EIR).

i i i ) One-‐Time Emissions

One-‐time emissions are those emissions that are not reoccurring over the life of the project. This includes emissions associated with construction, and emissions associated with land use changes. The emission estimation methodology for both construction and vegetation changes are described in Appendix G to this Draft EIR. The maximum daily emissions are not expected to be higher than that estimated given the conservative assumptions included in this analysis.

B. Thresholds of Significance

i ) Appendix G to the State CEQA Guidelines

In accordance with guidance provided in Appendix G to the State CEQA Guidelines, the Project could have a significant impact if it were to:

a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; or

b) Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

Furthermore, as described in Section 15064.4(b) of the State CEQA Guidelines, this analysis considers the following factors, among others, when assessing the significance of impacts fro GHG emissions on the environment:

(1) The extent to which the project may increase or reduce greenhouse gas emissions as compared to the existing environmental setting.

(2) Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.

(3) 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 greenhouse gas emissions.

i i ) City of Los Angeles CEQA Thresholds Guide

The L.A. CEQA Thresholds Guide does not provide any guidance as to how climate change issues are to be addressed in CEQA documents.

44 South Coast Air Quality Management District, 2013, California Emissions Estimator Model User’s Guide,

Version 2013.2.2 July 2013, website: http://www.CalEEMod.com/, accessed: November 2014.



i i i ) SCAQMD Tiered Significance Thresholds

In April 2008, SCAQMD convened a Working Group to develop GHG significance thresholds. On December 5, 2008, the SCAQMD Governing Board adopted its staff proposal for an interim CEQA GHG significance threshold for projects where the SCAQMD is the lead agency. The Board has, to date, only adopted an interim threshold of 10,000 MTCO2E per year for industrial stationary source projects.45 For all other projects, SCAQMD staff proposed a multiple tier analysis to determine the appropriate threshold to be used. The draft proposal suggests the following tiers: Tier 1 is any applicable CEQA exemptions, Tier 2 is consistency with a GHG reduction plan, Tier 3 is a screening value or bright line, Tier 4 is a performance based standard (i.e., it considers whether the project generates GHG emissions in excess of applicable performance standards for the project service population [population plus employment], and Tier 5 is GHG mitigation offsets.46

According to the presentation given at the September 28, 2010 Working Group meeting, SCAQMD staff reviewed the tiered significance threshold approach.47 The proposed tiers are as follows:

• Tier 1: Determine if CEQA categorical exemptions are applicable. If not move to Tier 2;

• Tier 2: Consider whether or not the proposed project is consistent with a locally adopted GHG reduction plan (often called a Climate Action Plan) that has gone through public hearings and CEQA review, which has an approved inventory that includes monitoring, etc. If not, move to Tier 3;

• Tier 3: For all land use types, if projects are less than 3,000 metric tonnes/year of carbon dioxide equivalents (MTCO2e/year), the project is presumed to be less than significant for GHGs. If the project exceeds 3,000 metric tonnes of MTCO2e/year, move to Tier 4. More specific screening thresholds were also provided, which include 1,400 MTCO2e/year for commercial projects and 3,500 MTCO2e/year for residential and mixed use projects. These thresholds were based on a review of the Office of Planning and Research database which included 711 CEQA projects using a 90% capture approach;

• Tier 4: The proposed performance standards include three options:

1. Percent Emission Reduction Target (no further recommendation);

2. Early Implementation of Applicable AB 32 Scoping Plan Measures (incorporated into option 3); and

3. SCAQMD Efficiency Target.

45 South Coast Air Quality Management District, Board Meeting Date: December 5, 2008, Agenda No. 31, Interim

CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans for use by the AQMD, website. website: http://www.aqmd.gov/home/governing-‐board/agendas-‐minutes, accessed: September 30, 2015.

46 Ibid. 47 South Coast Air Quality Management District, 2010. CEQA Significance Thresholds Working Group Meeting

#15, September 28, website: http://www.aqmd.gov/docs/default-‐source/ceqa/handbook/greenhouse-‐gases-‐(ghg)-‐ceqa-‐significance-‐thresholds/year-‐2008-‐2009/ghg-‐meeting-‐15/ghg-‐meeting-‐15-‐minutes.pdf?sfvrsn=2, accessed: September 30, 2015.



For option 3, there are targets for 2020 and 2035, using an approach similar to the Bay Area Air Quality District Thresholds.

The proposed 2020 target is:

o 4.8 MT/year CO2e per service population for project level threshold (land use employment only); and

o 6.6 MT/year CO2e per service population for plan level threshold.

The proposed 2035 target is:

o 3.0 MT/year CO2e per service population for project level threshold;

o 4.1 MT/year CO2e per service population for plan level threshold; and

o Incorporate Sustainable Communities and Climate Protection Act of 2008 or Senate Bill 375 (SB 375) regional targets.

• Tier 5: Off-‐site mitigation for life of project (30 years), if this threshold is to be used, GHG emissions must be mitigated to less than the Tier 3 screening significance threshold. The SCAQMD clarified that offsets should have a 30-‐year project life, should be real, quantifiable, verifiable, and surplus and will be considered in the following prioritized manner:

o Project design feature/onsite reduction measures;

o Offsite within neighborhood;

o Offsite within district;

o Offsite within state;

o Offsite out of state; and

o Substitution allowed via enforceable commitment (e.g. when an offset project ends prematurely).

If the proposed project cannot meet any of the tiers, it is presumed to be significant for GHG emissions.

The Tier 4 percent emission reduction target is based on a percent reduction target that is based on consistency with AB 32 as it was based on the same numeric reductions calculated in the Scoping Plan to reach 1990 levels by 2020.

The Working Group has not convened since the fall of 2010. The proposal has not yet been considered or approved for use by the SCAQMD Board. In the meantime, no GHG significance thresholds are approved for use in the Basin.

C. Project Impacts

Threshold (a): The Project could have a significant impact if it were to generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.

Impact (a): A less-‐than-‐significant impact associated with GHG emissions would occur.



The following discussion presents the analyses of construction and operational GHG emissions. Although the construction and operational GHG emissions discussions are presented separately, the level of impact is determined by combining both the construction and operational emissions. As such, a “Combined Impact” subheading is included below.

1) Construction

The construction of the Project would begin in 2016 and would be completed in 2018. The key construction phases included in this analysis are:

• Demolition -‐ involves tearing down of buildings or structures, and removal of any paving and asphalt.

• Site Preparation -‐ involves clearing vegetation (grubbing and tree/stump removal) and stones prior to grading.

• Grading -‐ involves the cut and fill of land to ensure the proper base and slope for the construction foundation.

• Building Construction -‐ involves the construction of structures and buildings.

• Architectural Coating -‐ involves the application of coatings to both the interior and exterior of buildings or structures.

• Paving -‐ involves the laying of concrete or asphalt for walkways, parking lots, or roads.

GHG emissions from these construction phases are largely attributable to fuel use from construction equipment and worker commuting. This analysis used CalEEMod™ version 2013.2.2 to quantify the construction emissions. The construction schedule, off-‐road equipment lists and equipment specifications, and daily trip counts for workers, vendors, and haul trucks as estimated for the Project are included in the analysis. CalEEMod™ default values were used for equipment and vehicle emission factors, equipment load factors, and vehicle trip lengths.

This analysis was based on a mix of Project-‐specific estimates and CalEEMod defaults for the numbers and types of equipment that will be used in the construction of the Project as well as the duration of the different construction phases. The GHG calculations are intended to estimate long-‐term emissions. The construction land area, schedule and equipment lists, and grading information, are in Appendix G.

The emission calculations associated with construction equipment are from off-‐road equipment engine use based on the equipment list and phase length. The fugitive emissions from off-‐road equipment performing work are also included in this analysis. The GHG emissions associated with off-‐road construction equipment are shown in Table IV.F-‐2 (Construction GHG Emissions).

Construction generates on-‐road vehicle exhaust, evaporative, and dust emissions from personal vehicles for worker and vendor commuting, and trucks for soil and material hauling. These emissions are based on the number of trips and vehicle miles travelled (VMT) along with emission factors from EMFAC2011. The GHG emission from on-‐road vehicles associated with construction is shown in Table IV.F-‐2.



The total emissions from construction are summarized in Table IV.F-‐2. Total GHG emissions from all construction phases for off-‐road and on-‐road emissions are 896 and 2,589 MT CO2e, respectively. When amortized over 30-‐year project lifetime, the construction GHG emissions are 116 MT CO2e/year.48 Detailed emission inventory from the CalEEMod™ output files are included in Appendix G.

Table IV.F-‐2 Construction GHG Emissions

(MT CO2e)

Calendar Year Total Off-‐Road

Emissions

Total On-‐Road Emissions Total Construction Emissions Worker Vendor Hauling

2016 329 213 123 997 1,661 2017 471 668 413 0 1,552 2018 96 109 67 0 271 Total 896 990 602 997 3,485

30-‐Year Amortized 116 Notes: Construction emissions include on-‐site and off-‐site (worker/vendor/hauling) emissions, estimated using CalEEMod v2013.2.2 or methodologies described it the text. CO2e includes CO2, CH4, and N2O emissions, weighted by their respective global warming potentials. Source: Ramboll ENVIRON US Corporation, May 2015.

2) Operation

1) Vegetation Changes

Permanent vegetation changes that occur as a result of Project development constitute a one-‐time change in the carbon sequestration capacity of a project. In this case, developed land would be converted to different land uses with additional landscaped areas with trees and vegetation. This would result in an overall net gain of carbon sequestration once the vegetation reaches a steady state (i.e., new vegetation replaces dying vegetation). Consequently, vegetation change results in decrease in overall GHG emissions.

The change in vegetation at the Project Site results in a one-‐time net sequestration of carbon (see Appendix G). The Project CO2e sequestered emissions was estimated to be 3.23 MTCO2e. In other words, the Project is estimated to sequester a total of 3.23 MTCO2e or 0.11 MTCO2e per year if amortized over a 30-‐year project lifetime.

2) Annual Operational Emissions

Emissions from mobile and area sources and indirect emissions from energy and water use, wastewater, as well as waste management, would occur every year after buildout. The following discussion addresses the operational GHG emissions.

48 This approach to one-‐time construction and vegetation change GHG emissions is based on the GHG Threshold

Working Group Meeting #13 Minutes from August 26, 2009, website: http://www.aqmd.gov/docs/default-‐source/ceqa/handbook/greenhouse-‐gases-‐(ghg)-‐ceqa-‐significance-‐thresholds/year-‐2008-‐2009/ghg-‐meeting-‐13/ghg-‐meeting-‐13-‐minutes.pdf?sfvrsn=2, accessed: September 30, 2015.



a. Area Sources

Area sources in CalEEMod consist of direct sources of air and GHG emissions. Area sources with GHG emissions relevant to the Project include emissions from hearths and landscape maintenance equipment. The area source GHG emissions included in this analysis result from landscaping-‐related fuel combustion sources, such as lawn mowers. For purposes of this analysis, the Project is assumed to include natural gas fireplaces in 89.5 percent dwelling units based on CalEEModTM defaults.49 GHG emissions due to natural gas combustion in buildings other than from fireplaces are excluded from this section since they are included in the emissions associated with building energy use.

The GHG emissions for the Project were calculated using CalEEMod™ defaults based upon the land uses that would be part of the Project, except that all cooking stoves were assumed to burn natural gas, based on SCAQMD Rule 445. The resulting GHG emissions for the Project are shown in Table 9 of Appendix G.

b. Energy

GHGs are emitted from buildings as a result of activities for which electricity and natural gas are typically used as energy sources. Combustion of any type of fuel emits CO2 and other GHGs directly into the atmosphere; these emissions are considered to be direct emissions associated with a building. GHGs are also emitted during the generation of electricity from fossil fuels; these emissions are considered to be indirect emissions.

Energy use in buildings is divided into energy consumed by the built environment and energy consumed by uses that are independent of the construction of the building, such as in plug-‐in appliances. In California, Title 24 governs energy consumed by the built environment, mechanical systems, and some types of fixed lighting.50 Non-‐building energy use, or “plug-‐in” energy use can be further subdivided by specific end-‐use (e.g., refrigeration, cooking, office equipment, etc.). To calculate the building energy input for the Project (e.g., electricity, and natural gas), this analysis uses default values provided in CalEEMod™, which are based on the California Commercial End Use Survey and Residential Appliance Saturation Survey.51

CalEEModTM converts the resulting energy use quantities to GHG emissions by multiplying by the appropriate emission factors obtained by incorporating information on local electricity production. Unless otherwise noted, CalEEMod™ default parameters were used. The energy-‐related emissions include project design features such as, installation of Energy Star appliances for the Project. The Energy Star commitment includes appliances such as, clothes washers, dishwashers, refrigerators, and fans and the improved energy efficiency is based on CalEEMod default assumptions. These appliances reduce GHG emissions associated with reduced electricity use. Therefore, the CO2e emissions from electricity and natural gas uses were estimated to be 2,656 and 364 MTCO2e/year, respectively, or 3,020 MTCO2e/year total (see Appendix G). 49 Wood-‐burning fireplaces and stoves are largely prohibited in the South Coast Air District as of March 9, 2009.

Rule 445. 50 Title 24, Part 6, of the California Code of Regulations: California's Energy Efficiency Standards for Residential

and Nonresidential Buildings, website: http://www.energy.ca.gov/title24/. 51 A detailed explanation how the Residential Appliance Saturation Survey and California Commercial End Use

Survey data was processed for use in CalEEMod is available in CalEEMod User’s Guide Appendix E pages 27-‐32.



Additionally, energy use (i.e., electricity and natural gas) by swimming pools is calculated from the City of Oakland Energy Efficient Commercial Pool Program Preliminary Facility Reports. The estimated emissions from the swimming pools is 21 MTCO2e/year (see Appendix G).

c. Water

Indirect GHG emissions result from the production of electricity used to convey, treat, and distribute water and wastewater. The amount of electricity required to convey, treat, and distribute water depends on the volume of water as well as the sources of the water. Additional emissions from wastewater treatment include CH4 and N2O, which are emitted directly from the wastewater.

The analysis assumes a 20 percent reduction through the use of water saving fixtures and or flow restrictors as required by the California Green Building Standards Code. GHG emissions related to the water and wastewater conveyance were based on the utility emission factors consistent with the Project analysis.

The Project was estimated to have 52 and 38 Mgal/year (million gallons per year) of indoor and outdoor water use and was estimated to result in 492 MTCO2e/year as shown in Table 13 in Appendix G.

d. Solid Waste

Municipal solid waste is the amount of material that is disposed of by land filling, recycling, or composting. CalEEModTM calculates the indirect GHG emissions associated with waste that is disposed of at a landfill. The program uses annual waste disposal rates from the California Department of Resources Recycling and Recovery (CalRecyle) data for individual land uses. The emission estimates in this Project were based on CalEEModTM default factors. CalEEModTM uses the overall California Waste Stream composition to generate the necessary types of different waste disposed into landfills. The program quantifies the GHG emissions associated with the decomposition of the waste, which generates methane based on the total amount of degradable organic carbon. The program quantifies the CO2 emissions associated with the combustion of methane, if applicable.

The analysis assumes the CalEEMod default waste diversion assumptions. This is a conservative estimate, as additional waste will likely be diverted from landfills by a variety of means, such as reducing the amount of waste generated, recycling, and/or composting to meet the statewide goal of 75 percent waste diversion.52 The CalEEMod™ solid waste module determines the GHG emissions associated with the disposal of solid waste into landfills, in quantities that are based upon land use type according to waste disposal studies conducted by CalRecycle. For this module, CalEEMod™ default waste generation and disposal rates were used since site specific information was not available. GHG emissions associated with non-‐landfill diverted waste streams are not considered, because it is generally assumed that these diversions do not result in any appreciable amounts of GHG emissions when operated effectively.53 These waste diversion alternatives may result in differences in life-‐cycle emissions of GHGs,

52 CalRecycle, 2013. California’s 75 Percent Initiative, website: http://www.calrecycle.ca.gov/75percent/,

accessed: December 2014. 53 California Air Resources Board, 2010, Local Government Operations Protocol, Chapter 9.4.



but it is not appropriate to combine life-‐cycle emissions for only one category of emissions.54 As mentioned previously, biogenic CO2 emissions were not included when CARB analyzed the GHG emissions inventory under AB 32. Therefore, they are not included in the Project emissions inventory.

The Project was estimated to generate 556 tons/year of solid waste and was estimated to result in 253 MTCO2e/year as shown in Table 14 in Appendix G.

e. Mobile Sources

The GHG emissions associated with on-‐road mobile sources are generated from residents, workers, customers, and delivery vehicles visiting the land use types in the Project. The emissions from on-‐road mobile sources includes running and starting exhaust emissions, evaporative emissions, brake and tire wear, and fugitive dust from paved and unpaved roads. Starting and evaporative emissions are associated with the number of starts or time between vehicle uses and the assumptions used in determining these values are described below. All of the other emissions are dependent on VMT. This analysis estimated traffic emissions using the Transportation Demand Management (TDM) adjusted trip rates in the Transportation Analysis Report55 (Appendix J). Fehr and Peers estimated the TDM reduction to be 10 percent for peak hour trips; and, as a conservative assumption, the TDM reduction for daily trips is 9 percent.

The analysis includes the benefit of reductions from the regulatory programs such as Pavley, LCFS, and Advance Clean Cars. The Pavley Standard required CARB to adopt regulations by January 1, 2005, to reduce GHG emissions from non-‐commercial passenger vehicles and light-‐duty trucks of model year 2009 and thereafter. The CalEEModTM model includes emission reductions for non-‐commercial passenger vehicles and light-‐duty trucks of model year 2017 – 2025. Executive Order S-‐01-‐07 (January 18, 2007) requires a 10 percent or greater reduction in the average fuel carbon intensity for transportation fuels in California regulated by CARB. The regulation went into effect on April 15, 2010, and requires a reduction in the carbon intensity of transportation fuels used in California by at least 10 percent by 2020. It imposes fuel requirements on fuel sold in California, which will decrease GHG emissions by reducing the full fuel-‐cycle and the carbon intensity of the transportation fuel pool in California. Reductions due to LCFS were further applied to CO2 emission factors after adjustments from the Pavley Standard for scenario years 2011 and after. This is also included in the CalEEModTM model. The Advanced Clean Cars program introduced in 2012, combines the control of smog, soot-‐causing pollutants and GHG emissions into a single coordinated package of requirements for model years 2015 through 2025. This regulation has not been incorporated into CalEEModTM, and thus an estimate of the GHG emission reductions from the Advanced Clean Cars program were estimated separately.

In CalEEmodTM, the trip type breakdown describes the purpose of the trip generated at each land use. For example, the trip type breakdown indicates the percentage of trips generated at single-‐family home

54 This inventory represents scope 1 and 2 emission categories. A life-‐cycle analysis of waste diversion would be a

scope 3 inventory. CARB’s Local Government Operations Protocol Version 1.1 (May 2010) clearly states that scope 3 emissions should not be combined with scope 1 and 2 emissions.

55 Fehr & Peers, Academy Arts Development Project – Transportation Analysis Report, February 2015.



for work, for shopping, and for other purposes. Two sets of trip type breakdowns are used in CalEEModTM.56

• Residential Trips – These trips include home-‐work (H-‐W), home-‐shop (H-‐S), or home-‐other (H-‐O). An H-‐W trip represents the trip from the home to the workplace. An H-‐S trip represents the trip from the home to a land use were shopping takes place (generally retail). An H-‐O represents all other types of trips generated by the resident, such as school, entertainment, etc. The trip type breakdown in CalEEModTM is from district-‐supplied information or the 1999 Caltrans Statewide Travel Survey is used as default or specific information obtained from the various districts.

• Commercial Trips – These trips include commercial-‐customer (C-‐C), commercial-‐work (C-‐W) and commercial-‐nonwork (C-‐NW). A C-‐C trip represents a trip made by someone who is visiting the commercial land use to partake in the services offered there. The C-‐W trip represents a trip made by someone who is employed by the commercial land use. The C-‐NW trip represents a trip associated with the commercial land use other than by customers or workers. An example of C-‐NW trips includes trips made by delivery vehicles of goods associated with the land use. The trip type breakdown from the number or workers and or truck trips from Institute of Transportation Engineers and an analysis of information provided for the South Coast Air Basin was used as default to assign the trip type breakdowns for all land uses in CalEEModTM.

The estimated trip length is based on the Fehr and Peers analysis for the weekday total VMT. The estimated trip length is calculated by dividing daily VMT by total daily trips. Based on the Project’s Transportation Analysis Report (see Appendix J), there may be trip reductions due to:

• Transportation Demand Management measures, including:

o Wide sidewalks and pedestrian plazas/paseos accessible to the neighborhood.

o Street trees and landscaped pathways between buildings.

o Improved street and pedestrian lighting.

• Specific intersection improvements, including physical mitigation measures and signal phasing modifications.

The above-‐identified Transportation Demand Management measures would reduce trips by designing a pedestrian-‐oriented safe network that encourages and facilitates pedestrian transportation in lieu of vehicle trips. The accessibility of the pedestrian plazas/paseos to the neighborhood provide for a direct means for pedestrian travel to and from the Project Site, further discouraging the need or desire to use personal motorized transportation. The street trees and landscaped pathways between buildings and improved street and pedestrian lighting contribute toward an inviting pedestrian space that provides meaningful circulation throughout the site as well as to and from the site, and pedestrian safety.

As a conservative assumption, a trip reduction of 9 percent was applied to the daily trip rate.

56 South Coast Air Quality Management District, 2013, California Emissions Estimator Model User’s Guide,

Appendix A, page 20, Version 2011.1, February, website: http://www.CalEEMod.com/, accessed: November 2014.



Trip link types further describe the characteristics of the trip attracted to each land use, whether it is a primary trip, a diverted link trip, or a pass-‐by trip. For example, a commercial customer pass-‐by trip could be a person going from home to shop on his/her way to work. In addition, a commercial customer diverted-‐link trip could be a person going from home to work, and on its way making a diversion to shop. Pass-‐by trips generate virtually no additional running emissions but could generate additional resting and startup emissions. Diverted trips generate less running emissions compared to primary trips, and can also generate additional resting and startup emissions.

The Transportation Analysis Report (Appendix J) incorporated a reduction related to pass-‐by trips and it was conservatively assumed that there were no additional diverted trips. The trip rates, based on the traffic analysis, are shown in Table 15a in Appendix J.

The Project was estimated to generate approximately 14,238,416 VMT/year and was estimated to result in 5,666 MTCO2e/year as shown in Table 16a in Appendix G. The mobile source emissions include customer trips as evaluated by CalEEModTM. The Project was estimated to generate approximately 8,627,961 VMT/year. The estimated mobile source emissions if the customer trips are excluded are 3,433 MTCO2e/year, as shown in Table 16b in in Appendix G.

3) Combined Impact

Consistent with AB 32, this analysis compares the Project’s emissions to the SCAQMD draft efficiency target for 2020. The SCAQMD’s draft 2020 target for project-‐level analysis is 4.8 MT/year CO2e per service population (i.e., residents and employees). When assessing the Project’s GHG emissions with this methodology, the analysis used a modified emissions inventory to compare against the efficiency target because the SCAQMD’s draft definition of “service population” leads to a negative bias for projects with high numbers of “customers” or “visitors,” such as retail, restaurants, hospitals and medical offices. With the SCAQMD’s draft approach, the emissions from customers and visitors are included in the total emissions, but these customers and visitors are excluded from the service population. The modified emissions inventory used in this analysis evaluates the emissions associated with the defined service population; as such, mobile source emissions associated with customers and visitors are excluded from the emissions total.

The Project’s combined construction and operational emissions are estimated to be 7,388 metric tons (MT) CO2e/year and the Project’s efficiency metric (i.e., the Project’s GHG emissions divided by the service population) is estimated to be 3.91 MT/year CO2e per service population (see also the Tier 4 discussion under SCAQMD Tiered Significance Thresholds, above). Therefore, the Project would result in less-‐than-‐significant impacts as it would generate GHG emissions that are below the SCAQMD draft efficiency target of 4.8 MT/year CO2e per service population (see Table IV.F-‐3, Project GHG Emissions).

The service population is the residents and employees.



Table IV.F-‐3 Project GHG Emissions

Categorya CO2e Emissionsb

Area 58 Energy Use 3,020 Water Use 492 Waste Disposal 253 Traffic 3,433 Swimming Pool 21

Subtotal 7,278 Construction Amortized 116 Vegetation Amortized -‐6

Total 7,388 Service Population

Emissions per Service Population SCAQMD Efficient Metric Threshold Above Threshold?

1,890 3.91 4.8 No

Note: Totals may not add precisely due to rounding. a CO2e emissions were estimated using CalEEMod version 2013.2.2. b CO2e includes CO2, CH4, and N2O emissions, which are weighted by their respective global warming potentials. Source: Ramboll Environ US Corporation, May 2015.

Threshold (b): The Project could have a significant impact if it were to conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

Impact (b): A less-‐than-‐significant impact with respect to consistency with GHG plans, policies, and regulations would occur.

As discussed previously, the ARB AB32 Scoping Plan was developed to direct the State to reduce GHG emissions to 1990 levels. The measures from the ARB AB32 Scoping Plan are applicable to State, regional, and local agencies in the development of plans to reduce GHG emissions, but are not applicable to each and every new general development project. However, strategies and measures have been implemented on the State level by example of the 2013 Title 24 CALGreen Code and on the local level by the City of Los Angeles Green Building Code.

As discussed previously, the SCAQMD’s Tier 4 draft 4.8 MTCO2E per service population efficiency target was proposed based on the goal of AB 32 to reduce statewide GHG emissions to 1990 levels by 2020. As shown in the previous analysis, the Project would have an efficiency of 3.91 MTCO2e of GHGs per service population. Therefore, the Project would be consistent with the goals of AB 32. Further, the Project would be consistent with other plans, guidelines, and regulations, including the 2013 Title 24 CALGreen Code and the LA Green Building Code, and Green LA. Based on this information, the Project would not conflict with an applicable plan, policy or regulation for the purpose of reducing the emissions of GHGs. Therefore, the impact of the Project would be less than significant.

4. CUMULATIVE IMPACTS

The geographic extent of GHG emissions is global, and the effect of these emissions on global climate change is potentially worldwide. As discussed above, emitting GHGs into the atmosphere is not itself an



adverse environmental effect. Rather, it is the increased accumulation of GHGs in the atmosphere that may result in global climate change; the consequences of which may result in adverse environmental effects. The State has mandated a goal of reducing statewide emissions to 1990 levels by 2020. As discussed above, the Project would have an efficiency of 3.91 MTCO2e of GHGs, which would be less than the SCAQMD’s draft threshold of 4.8 MTCO2e per service population, and, therefore, determined to be a less-‐than-‐significant impact. This efficiency target was established based on the goal of AB 32 to reduce statewide GHG emissions to 1990 levels by 2020. Moreover, because of the global scale of climate change, any one project’s contribution is unlikely to be significant by itself. For many air pollutants, the significance of their environmental impact may depend greatly on where they are emitted; however, for GHG is does not. The fact that carbon dioxide and other GHGs, once released into the atmosphere, are not contained in the local area of their emissions means that the impacts are also global rather than local. The impact of the proposed Project in addition to the related projects are not directly relevant to the determination of a cumulative impact because of the complex physical, chemical, and atmospheric mechanisms involved in global climate change. Similar to the proposed Project, the related projects are reasonably anticipated to demonstrate compliance with applicable plans, policies, and guidelines addressing GHG emissions and climate change, which would further reduce GHG emissions to the extent feasible and appropriate. Furthermore, the GHG emissions from the Project and the related projects would be negligible compared to the State or global GHG emissions. As such, the GHG emissions of the Project in combination with the related projects would not result in a cumulatively significant impact.

5. MITIGATION MEASURES

The Project would result in a less-‐than-‐significant impact to GHG emissions, as the Project would be consistent with the State’s programs to achieve specific GHG emissions reductions, as reflected in the assumptions set forth above. Furthermore, many of the project design features listed throughout Section IV.N (Utilities and Energy) would support the reduction of GHG emissions, including LEED Gold certification for the proposed office buildings and LEED Silver certification for the proposed residential building. Nonetheless, the following mitigation measure is recommended to further reduce the less-‐than-‐significant impact and reflect good planning practices currently promoted by the City.

MM GHG-‐1 To encourage carpooling and the use of electric vehicles by Project residents and visitors, at least twenty (20)% of the total code-‐required parking spaces provided for all types of parking facilities, but in no case less than one location, shall be capable of supporting future electric vehicle supply equipment (EVSE). Plans shall indicate the proposed type and location(s) of EVSE and also include raceway method(s), wiring schematics and electrical calculations to verify that the electrical system has sufficient capacity to simultaneously charge all electric vehicles at all designated EV charging locations at their full rated amperage. Plan design shall be based upon Level 2 or greater EVSE at its maximum operating ampacity. Only raceways and related components are required to be installed at the time of construction. When the application of the 20% results in a fractional space, round up to the next whole number. A label stating “EV CAPABLE” shall be posted in a conspicuous place at the service panel or subpanel and next to the raceway termination point.

6. LEVEL OF SIGNIFICANCE AFTER MITIGATION

Impacts associated with GHG emissions from the Project would be less than significant.