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City of San Leandro <br />311 MacArthur Boulevard Residential Project <br /> <br />46 <br />(2015) 62 Cal. 4th 204). Given the legislative attention and judicial action regarding post-2020 goals <br />and the scientific evidence that additional GHG reductions are needed through the year 2050, the <br />Association of Environmental Professionals’ Climate Change Committee published a white paper in <br />October 2016 to provide guidance on defensible GHG thresholds for use in CEQA analyses and GHG <br />reduction targets in climate action plans in light of the change in focus on the 2030 reduction target <br />and questions raised in the Newhall Ranch case. <br />The white paper identified seven thresholds for operational emissions. The following four methods <br />described are the most widely used evaluation criteria.2 <br />(1) Consistency with a Qualified GHG Reduction Plan. For a project located within a jurisdiction <br />that has adopted a qualified GHG reduction plan (as defined by CEQA Guidelines Section <br />15183.5), GHG emissions would be less than significant if the project is anticipated by the <br />plan and fully consistent with the plan. However, projects with a horizon year beyond 2020 <br />should not tier from a plan that is qualified up to 2020. <br />(2) Bright line Thresholds. There are two types of bright line thresholds: <br />a. Standalone Threshold. Emissions exceeding standalone thresholds would be considered <br />significant. <br />b. Screening Threshold. Emissions exceeding screening thresholds would require <br />evaluation using a second tier threshold, such as an efficiency threshold or other <br />threshold concept to determine whether project emissions would be considered <br />significant. <br />However, projects with a horizon year beyond 2020 should take into account the type and <br />amount of land use projects and their expected emissions out to the year 2030. <br />(3) Efficiency Thresholds. Land use sector efficiency thresholds are currently based on <br />Assembly Bill (AB) 32 targets and should not be used for projects with a horizon year <br />beyond 2020. Efficiency metrics should be adjusted for 2030 and include applicable land <br />uses. <br />(4) Percent Below “Business as Usual” (BAU). GHG emissions would be less than significant if <br />the project reduces BAU emissions by the same amount as the statewide 2020 reductions. <br />However, this method is no longer recommended following the Newhall Ranch ruling. <br />Operational emissions methods (1), (2), and (4) were not applicable. The City of San Leandro <br />maintains a Climate Action Plan (CAP) with a horizon year of 2020 and does not appear to be <br />qualified per the requirements of CEQA Section 15183(5).Because the project has a horizon year <br />beyond 2020 and the CAP does not appear to be qualified, the CAP cannot be used for project <br />tiering. This applies to bright line thresholds provided in the CAP. Furthermore, BAU emissions are <br />no longer recommended following the Newhall Ranch ruling. <br />With the release of the 2017 Climate Change Scoping Plan Update, CARB recognized the need to <br />balance population growth with emissions reductions and in doing so, provided a new local plan <br />level methodology for target setting that provides consistency with state GHG reduction goals using <br /> <br />2 The three other thresholds are best management practices/best available mitigation, compliance with regulations, and a hybrid <br />threshold concept: separate transportation and non-transportation threshold. These are not commonly used and do not specifically apply <br />to this project.