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4 Environmental Analysis 4.8 Greenhouse Gas Emissions estimate the GHG emissions during construction and operation of the proposed Project. Total construction emissions from the Project were annualized over a Project life of 30 years to derive amortized annual emissions and combined with the Project's annual operational emissions derived from CaIEEMod for comparison with CAPCOA's threshold. Project emissions of CO2, CH4, and N2O were multiplied with their respective global warming potentials of 1, 25, and 298 and summed together to estimate CO2e emissions. Additionally, Project GHG emissions would include fugitive emissions of SF6 from high-voltage circuit breakers at the onsite substation. The SF6 GWP is equivalent to 22,800 times that of CO2. CO2, emissions resulting from SF6 gas leakage at the Project were estimated for the two high-voltage circuit breakers, each with a capacity of up to 160 pounds of SF6 for a total of up to 320 pounds, assuming a maximum leak rate of 0.5 percent per year. The R-134A GWP is 1,430 times that of CO2. The Project will have approximately 500 battery storage units with a leak rate of approximately 0.035 pounds of R-134A per unit. 4.8.4 Thresholds of Significance Under CEQA, a project would have a significant impact to GHG emissions if it would: 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. In the Guidance for Valley Land-Use Agencies in Addressing GHG Emission Impacts for New Projects Under CEQA and the policy Addressing GHG Emission Impacts for Stationary Source Projects Under CEQA When Serving as the Lead Agency (SJVAPCD 2009a), BPS are used to assess significance of project-specific GHG emissions on global climate change during the environmental review process. However, the SJVAPCD's adopted BPS are specifically directed at reducing GHG emissions from stationary sources; therefore, the adopted BPS would not generally be applicable to the Project as the Project would not be a stationary source of emissions. 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. The SJVAPCD supports the use of the interim thresholds as established by CAPCOA when adopted thresholds are not applicable. A new threshold has not been established to meet SB 32 targets beyond 2020. 4.8.5 Impacts Analysis IMPACT 4.8-1: Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? (Less Than Significant Impact); and IMPACT 4.8-2: Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? (No Impact) Construction Emissions Construction of the Project would increase GHG generation, which can contribute to global climate change. This analysis is provided in response to recent heightened interest in the subject Griffith Energy Storage Project 4.8-9 Tetra Tech/SCH 2022120675 Draft Environmental Impact Report August 2023