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4.5 – Greenhouse Gas Emissions Draft Environmental Impact Report February 2021 14800 W. Schulte Road Logistics Center 4.5-24 Furthermore, the advisory document indicates that “in the absence of regulatory standards for GHG emissions or other scientific data to clearly define what constitutes a ‘significant impact,’ individual lead agencies may undertake a project-by-project analysis, consistent with available guidance and current CEQA practice” (OPR 2018). Section 15064.7(c) of the CEQA Guidelines specifies that “when adopting thresholds of significance, a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies, or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence.” Notwithstanding the CEQA Guidelines, local land use agencies sought additional technical assistance from expert air quality agencies in how to complete the suggested quantitative analysis of the significance of GHG emissions for land use projects being considered under CEQA. The SJVAPCD adopted Guidance for Valley Land-Use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA (SJVAPCD 2009b). The guidance relies on either BPS or 29% reduction compared to BAU to assess the significance of project-specific GHG emissions on global climate change during the environmental review process. Notably, the Project would not be considered a stationary project with applicable BPSs. Regarding the BAU threshold, the Supreme Court in its 2015 decision, Center for Biological Diversity v. Department of Fish and Wildlife, S217763 (Newhall), concluded that substantial evidence is required to support the application of AB 32 statewide GHG reduction goal of 29% to new land use projects. Since neither the BPS nor BAU approach is generally appropriate for this Project, the SJVAPCD guidance was not used for this analysis. However, the SJVAPCD guidance does not limit a lead agency’s authority in establishing its own process and guidance for determining significance of project-related impacts on global climate change. In absence of any applicable numeric threshold, this analysis assesses compliance with applicable plans, policies, regulations, and requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. As a land use development project, the most directly applicable adopted regulatory plan to reduce GHG emissions is the SJCOG 2018 RTP/SCS, which is designed to achieve regional GHG reductions from the land use and transportation sectors as required by SB 375 and the state’s long-term climate goals. This analysis also considers consistency with regulations and requirements adopted pursuant to the Scoping Plan and the County’s General Plan. GHG emissions from Project construction and operation are included for disclosure, consistent with the Governor’s Office of Planning and Research recommendations and industry practice. Approach and Methodology Project Design Features The following project design features (PDFs) would be included as part of the Project: PDF-AQ/GHG-1 The buildings shall be designed to achieve a minimum the Leadership in Energy and Environmental Design (LEED) Certified goal identified by the LEED Green Building Rating System to conserve resources, including but not limited to energy and renewable resources. PDF-AQ/GHG-2 Install 2%–3% skylights in warehouse buildings for natural lighting and reduce electricity consumption from warehouse lighting. PDF-AQ/GHG-3 Install conduit for future electric truck charging capabilities. PDF-AQ/GHG-4 Install conduit for 33 future electric vehicle charging spaces. PDF-AQ/GHG-5 Designate 21 parking spaces for clean air/electric vehicle/vanpool parking.