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Administrative Draft Environmental Impact Report <br /> Gill Medical Center Project <br /> a note,the CEQA Guidelines were amended in response to Senate Bill 97. In particular, the CEQA <br /> Guidelines were amended to specify that compliance with a GHG emissions reduction plan renders a <br /> cumulative impact insignificant. <br /> Per CEQA Guidelines Section 15064(h)(3), a project's incremental contribution to a cumulative impact can <br /> be found not cumulatively considerable if the project would comply with an approved plan or mitigation <br /> program that provides specific requirements that would avoid or substantially lessen the cumulative <br /> problem within the geographic area of the project.To qualify, such plans or programs must be specified <br /> in law or adopted by the public agency with jurisdiction over the affected resources through a public <br /> review process to implement, interpret, or make specific the law enforced or administered by the public <br /> agency. Examples of such programs include a "water quality control plan, air quality attainment or <br /> maintenance plan, integrated waste management plan, habitat conservation plan, natural community <br /> conservation plans [and] plans or regulations for the reduction of greenhouse gas emissions." Put another <br /> way, CEQA Guidelines Section 15064(h)(3) allows a lead agency to make a finding of less than significant <br /> for GHG emissions if a project complies with adopted programs, plans, policies and/or other regulatory <br /> strategies to reduce GHG emissions. <br /> The local air quality agency regulating the San Joaquin Valley Air Basin (SJVAB) is the SJVAPCD, the <br /> regional air pollution control officer for the basin. As previously stated, the SJVAPCD has adopted <br /> guidance and policy for analyzing GHG emissions from land use development projects under CEQA. <br /> Specifically, demonstration of a 29 percent reduction in GHG emissions, from a BAU scenario is required <br /> to determine that a project would have a less than cumulatively significant impact. However, as previously <br /> described the BAU portion of the tiered approach is problematic based on the 2015 California Supreme <br /> Court Newhall Ranch decision,which stated that an GHG-related impact determination based on the BAU <br /> approach is "not supported by a reasoned explanation based on substantial evidence." Additionally, the <br /> SJVAPCD thresholds were adopted to achieve statewide GHG-reduction goals for the year 2020, and the <br /> Proposed Project would not be built until after the year 2020. <br /> The significance of the Project's GHG emissions is evaluated consistent with CEQA Guidelines <br /> § 15064.4(b)(2) by considering whether the Project complies with applicable plans, policies, regulations <br /> and requirements adopted to implement a statewide, regional, or local plan for the reduction or <br /> mitigation of GHG emissions. The County General Plan has established GHG reduction goals for 2035 and <br /> 2050. To achieve these goals the County has adopted policies, programs, and reduction strategies in the <br /> General Plan.Additionally, the projected regional development pattern in the SJCOGRTP/SCS, including <br /> location of land uses and residential densities in local general plans, when integrated with the proposed <br /> regional transportation network identified in the RTP/SCS, would reduce per capita vehicular travel— <br /> related GHG emissions and achieve state-mandated GHG reduction per capita targets for the SJCOG <br /> region. Thus, the Project is compared for consistency with both the County General Plan and <br /> SJCOGRTP/SCS in order to determine its GHG-related impact. <br /> 4.10.3.2 Methods of Analysis <br /> Onsite construction (including worker commutes and vendors), operational area source, and energy <br /> source, water/wastewater pumping, and solid waste hauling and decomposition emissions were modeled <br /> Greenhouse Gas and Climate Change 4.10-9 October 2021 <br />