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10 <br /> <br /> <br />The DEIR concludes that the Project would result in a significant-and-unavoidable GHG impact, stating: <br />“The analysis showed that the proposed project would have a significant GHG impact and as <br />such would be considered to have cumulatively significant impact as well. Feasible and <br />enforceable mitigation with a nexus to the project’s impact have been identified under Impacts <br />GHG-1 and GHG-2; however, even with implementation of all feasible mitigation, project <br />impacts would be significant” (p. 3.7-28). <br />The DEIR claims that the Project aligns with BAAQMD requirements and design elements. According to <br />CEQA Guidelines § 15096(g)(2): <br />“When an updated EIR has been prepared for a project, the Responsible Agency shall not <br />approve the project as proposed if the agency finds any feasible alternative or feasible <br />mitigation measures within its powers that would substantially lessen or avoid any significant <br />effect the project would have on the environment.” <br />An impact can therefore only be labeled as significant-and-unavoidable after all available, feasible <br />mitigation measures are evaluated. While the DEIR incorporates MM GHG-1, GHG-2, and MM TRANS-2a <br />and TRANS-2b, there are additional measures that the DEIR fails to consider (p. 3.7-26, 3.7-27). To <br />reduce the Project’s GHG impacts to the maximum extent possible, additional feasible mitigation <br />measures should be incorporated, such as those suggested in the section of this letter titled “Feasible <br />Mitigation Measures Available to Reduce Emissions.”