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January 13.2009 Page physical envimnment. "Before the impacts ofa project can be assessed and mitigation measures considered, an EIR must describe the existing physical conditions in the environment. It k only against this baseline that any significant environmental effects can he determined An ag :ncy cannot evaluate the impacts ofa proposed project on "'some hypothetical. impacted future environment that might occur under existing general plan and/or zoning desigratiotts. instead. it must consider the existing physical environment and measure the impacts of its project against the current conditions, 1lere, the City takes the wrong approach in its DEIR. because it measures the Project's climate change impacts against a theoretical projection of future emissions under its 1996 general plan, not against the actual conditions existing today, In fact, the ©F1R fails to estimate or quantify the City's current greenhouse gas emissions. The City's threshold discussion states: "If. w thin the Planning Area, the bulldout of the proposed General Plan L pdate were to have the cumulative potential to decrease greenhouse gas emissions below otherwise expected future emissions. then the cumulative greenhouse gas emissions would he Icss than significant. fhe City a;setts that without impkmendng greenhouse as reduction measures identified in the proposed General flan Update, the Project's direct greenhouse Lias emissions would total 607.000 tons of CO:eq per year,'"' The City goes on to say that indirect emissions associated with the project will also increase, hut fails to quantify what thc increase will he. The City finds that the total emissions from huildout of the proposed General Plan Update will he appru:cimately 595,000 tons COteq per year, which is 12.000 tons COreq per year less than emissions projected under the existing policies." this small decrease in projected emissions is enough. tinder thc City's flawed threshold of significance, for the City to find that climate chang: impacts for the proposed General Plan Update will be less than significant.''` There are several resources that the City can use to estimate its current and projected grcenitouse gas emissions. CARB has issued protocols for estimating the emissions from local gtwenmlent operations. and its protocol for estimating community wide emissions is forthc lming.' fhe GOvt71LOr'S Office of Planning and Research (OI'R) has issued a Technical Advisor, which contains a fist of technical resources and modeling tools to estimate CMG emissions.“ Other sources of helpful information are the white paper issued by the California n Sec, ;.g. Pub. Res. Code. 21060.5: 14 Cat.Code Kegs. 15002 (g); 15125 (el, L 5126.2 rat. ]5360_ Cow ry •%l imuhor r. !:7 flonM County water ,a.g.mT (1999) 76 C'nl App. 4 931. 952. t' Mont'* School fur Don v. (.'iry of San Rr¢dorl(_2008) 161 Cal App.4th 989. 3005 (quoting Woud wart 1'urh Ikrnreowner. Ast Inc v ('ih• of Frrnnn (200?) 1.5O Cal. App.41h 683, 7091; see also Loctronnlentol 1'Tanrvng rf Ttrkwrmr ion ('outwit v County ofEl fkwtedo 1982) 131 Cal.App.3d 350. 358. "'DEW: at 3.10 -7. t Id at 3.10-14. Id Id The protocols are available at hnp.�:www.arb.ca.guvec. prolocols.focalgov'Gxalgoc.huh- The Itchnical Advisory is available at hap: vww. Ibm. conindex. cfrnduseactionpuhltcatems .hoatupu blicatitms c1'm..