Page 10 - northlake_appeal_20180423

Jodie Sackett, County of Los Angeles
June 16, 2017
Page 8

Greenhouse Gas Emissions

Here you refer to the Los Angeles County Climate Action Plan ("CCAP"), which has as its goal
reducing greenhouse gas ("GHG") emissions by at least 11 % below 2010 levels by 2020.
(DSEIR at 5.7-17.) You fail to mention that SB 32 significantly increased the statewide GHG
reduction goal, to 40% below 1990 levels by 2030, and demonstrating compliance with the
CCAP simply will not demonstrate that the Project will not conflict with the goals of SB 32. See
CCAP, § 3.2 at page 3-2 (providing only for reduction of 11%below2010 levels by 2020).

You assert at 5. 7-18 that the DSEIR can "tier off' of a programmatic analysis of GHG emissions
if it meets the requirements of Guidelines § 15183 .5. This would be true of the CCAP if it
demonstrated compliance with SB 32 but it does not. It is also definitely not true of the 2012
SCV AP because that document found significant and unavoidable impacts to GHGs. See
Guidelines§ 15183.5(b)(l)(B).

At 5.7-21 you claim you will measure the Project's compliance against Executive Orders S-3-05
and B-30-15, but you never actually do this, sidestepping them on the ground that they are not
regionally applicable. The same was argued as to AB 32 before, and the Supreme Court has
made more than clear now that assessment of its mandates in the context of CEQA is both
appropriate and necessary.

You ultimately calculate GHG emissions at 56,722 MTC02e per year, though you claim the
impacts of this number are insignificant. We disagree. This number is highly significant when
measured against SCAQMD's proposed thresholds of 1400 to 3500 MTC02e per year depending
on whether the Project is commercial, mixed use, or residential.

We also note you assert that the Project "is committing to the equivalent of installing solar power
equivalent to 3 kW per residential dwelling unit for 50 percent of the residential dwelling units."
We're not sure what this means. If solar power is not actually installed, for example if the
applicant purchases wind or solar credits for a specified number of years, this is not "equivalent."

At 5.7-37, you claim consistency with SCAG 2016-2040 RTP/SCS Goal 8, "Encourage land use
and growth patterns that facilitate transit and non-motorized transportation." We disagree that
the Project is consistent; there is little to no evidence that the Project is amenable to sustainable
work commutes.

At 5.7-43, Table 5.7-7, NorthLake Specific Plan GHG Emission Estimates, you compare a
hypothetical BAU scenario to the Project but you do not reflect the underlying assumptions for
the BAU numbers, and it is apparent that the reductions attributed to the Project are actually
reductions coming from other regulatory programs, not any mitigations imposed by the Project.
The Supreme Court recently disapproved of this tactic. The Table as a whole is highly
misleading, and the percentage reduction attributable to the Project is actually the difference
between the 66,083 MTC02e and the 56,722, or about 14.2%, not 40.1%.