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November 8, 2024 Page 23 7357-013acp printed on recycled paper are additional feasible mitigation measures which could reduce the Project’s GHG emissions impacts. The DEIR fails to analyze additional measures which could reduce the Project’s GHG emissions impacts to the greatest extent feasible.113 CEQA requires the lead agency to adopt feasible mitigation measures that will substantially lessen or avoid a project’s potentially significant environmental impacts and describe those mitigation measures in the EIR.114 The lead agency may not make the required CEQA findings regarding a project unless the administrative record demonstrates that it has adopted all feasible mitigation to reduce significant environmental impacts to the greatest extent feasible.115 SWAPE provides a list of potential GHG mitigation measures that may apply to the Project.116 The County must consider these and any other available feasible GHG mitigation measures that can further reduce the Project’s significant GHG emissions, and incorporate additional mitigation measures in a revised EIR circulated for public review and comment. Here, the Project results in significant GHG impacts from construction and operation of the proposed apartments and road improvements.117 The DEIR provides that “[p]rior to project operation, the proposed project would construct approximately 1,000 feet of off-site sidewalk improvements and bicycle lane improvements along Busch Road, which would connect to existing facilities on Busch Road and Ironwood Drive.”118 In order to mitigate these GHG impacts, SWAPE recommends BAAQMD recommended measures to reduce Project-related GHG emissions.119 The DEIR relies on Mitigation Measure MM TRANS-2b for transportation impacts, but determines the impacts are still significant and unavoidable. MM TRANS-2b provides that “Prior to project operation, the proposed project would construct approximately 1,000 feet of off-site sidewalk improvements and bicycle lane improvements along Busch Road, which would connect to existing facilities on Busch Road and Ironwood Drive.”120 But the DEIR also provides that “as part of the project’s design, the proposed project would construct approximately 1,000 feet of sidewalk and bicycle facilities improvements to fill in the sidewalk gaps on the north side of Busch Road between the project site and the existing sidewalk at 113 SWAPE Comments, p. 10. 114 PRC §§§ 21002, 21081(a) 21100(b)(3); CEQA Guidelines § 15126.4. 115 Covington v. Great Basin Unified Air Pollution Control Dist. (2019) 43 Cal.App.5th 867, 883. 116 SWAPE Comments, pp. 11-12. 117 SWAPE Comments, p. 12. 118 DEIR, p. ES-26. 119 SWAPE Comments, p. 12. 120 DEIR, p. 3.7-27.