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4.5 – Greenhouse Gas Emissions <br />Draft Environmental Impact Report February 2021 <br />14800 W. Schulte Road Logistics Center 4.5-23 <br />Policy NCR-5.12: Energy Efficient Industry. The County shall support energy efficiency of <br />industrial processes. <br />Policy NCR-5.13: Solar Heating in Industrial Operations. The County shall encourage industrial <br />operations that require large amounts of hot water to incorporate active solar <br />systems in the design of buildings. <br />4.5.3 Thresholds of Significance <br />The significance criteria used to evaluate a project’s impacts to GHG and climate change are based on Appendix G <br />of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to GHG <br />emissions would occur if a project would: <br />A. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on <br />the environment. <br />B. Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of <br />greenhouse gases. <br />C. Result in cumulatively considerable impacts with regard to greenhouse gas emissions. <br />Global climate change is a cumulative impact; a project participates in this potential impact through its <br />incremental contribution combined with the cumulative increase of all other sources of GHGs. There are <br />currently no established thresholds for assessing w hether the GHG emissions of a project would be considered <br />a cumulatively considerable contribution to global climate change; however, all reasonable efforts should be <br />made to minimize a project’s contribution to global climate change. In addition, although GHG impacts are <br />recognized exclusively as cumulative impacts (CAPCOA 2008), GHG emissions impacts must also be evaluated <br />on a project level under CEQA. <br />The CEQA Guidelines do not prescribe specific methodologies for performing an assessment, do not establish <br />specific thresholds of significance, and do not mandate specific mitigation measures. Rather, the CEQA Guidelines <br />emphasize the lead agency’s discretion to determine the appropriate methodologies and thresholds of significance <br />consistent with the manner in which other impact areas are handled in CEQA (CNRA 2009a). The State of California <br />has not adopted emissions-based thresholds for GHG emissions under CEQA. The Governor’s Office of Planning <br />and Research’s Technical Advisory, titled “Discussion Draft CEQA and Climate Change Advisory,” states the <br />following (OPR 2018): <br />Neither the CEQA statute nor the CEQA Guidelines prescribe thresholds of significance or particular <br />methodologies for perming an impact analysis. This is left to lead agency judgment and discretion, <br />based upon factual data and guidance from regulatory agencies and other sources where available <br />and applicable. Even in the absence of clearly defined thresholds for GHG emissions, such <br />emissions must be disclosed and mitigated to the extent feasible whenever the lead agency <br />determines that the project contributes to a significant, cumulative climate change impact.