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January 13,009 Page i Air Pclltttion Control Officers Association (CAPC'OA), "CEQA and Climate Change and the Attorney General's website, both of which provide information on currently available models der calculating emissions.. 2. Mitigation As proposed. the project will result in an increase in vehicle miles traveled of 46%, and devek potent of millions of square feet of commercial, office and other non- residential buildings. Although the City fails to properly calculate the increases in greenhouse gas emissions that will result from this growth and development, these emissions clearly will be significant. The City thus was required to adopt enforceable mitigation measures to lessen the project's greenhouse gas emissions, which it failed to do. 411 As drafted, the DEIR provides four optional measures to minimize the General Plan Updat_'s impacts on climate change. The options discussed in the City's DEIR, however, are not "Gully enforceable" and therefore, are not proper mitigation measures under C'EQA. For example, the City states that it will work with the International Council for Local Environmental Initiat.ves ICLEI) to develop an action plan capable of reducing the City's greenhouse gas emissions. However, the commitment is not concrete: it's not clear when it will begin working witlt I': LEI and even after the plan is developed, the City does not commit to enforcing the plan's provisions. Rather, the City says it will "consider implementing, monitoring, and report.ng appropriate and achievable components ot" the action plan. Similarly. the City offers m "crl.orrrage'• passive -solar constructions' Such voluntary measures are not entiorceahle and are not adequate to mitigate the climate Chang: impacts of the development that will take place under the General Plan Update over the next 17 years. Instead, the City should formulate specific ansihinding mitigationmcasures and include them in the General Plan Update. One approach would he for the City to immediately engage ICLEI to develop a fully enforceable Climate Action Plan, as numerous other jurisdictions in CAP:OA. CEQA and Climate Change, Evaluating arid Addressing Greenhouse Gas Emissiwrs from Protects Subject to the California Environmental Quality Atd I:Janwary Nita) f"CAPCOA white paper"), available* bop: +ry ww,capcoa orgi, Atn>rney General's website, available al hop: ag. Ca. gov :gluhalwoirmmgceganu+delrryt tools.php. 1 DDE111 at 3 I0.11., 3 10.14. Cal. 'ub, Res. Code, 4121002. 2I002.I Ib'), Omens of Goleta Valle) v. &'cord .JSry3entr,r.i (1990) 52 Cal.ld 553, 9 see 14 Cal. Code Regs. '415126.4(03) 'mitigation measures not required for impacts that are ins tuns icant). mitt a1 3.10 -15.3 1046 Cale 'tab. Res. Code. 210$1.61b): 14 Cal. Code Regs. 1509Itd): see alio Federatims ell' Ili/ lride andC;Lrrr:,r Asset .v. v. f)rs cJ L.r.frrxrles (2000) al CatApp,4th 1252, 1261 ',general plan EIR defective where (here was no substar bid evidence that mitigation measures would "actually he inrplemented (if' at 9-IL DEIR at 3.10-15, PEl It *3.10-15, Id.