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<br />Sequoia Ecological Consulting, Inc. <br />CalVTP Project-Specific Analysis and Addendum <br />Augustin Bernal Community Park Fuel Reduction <br />November 2025 <br />4-56 <br /> <br /> <br />4.7.1.2. Impact GHG-2 <br />The use of vehicles and mechanical equipment, prescribed herbivory, herbicide application, and <br />prescribed burning during initial and maintenance treatments would result in GHG emissions. However, <br />these treatments would have relatively low GHG emissions compared to GHG emissions from catastrophic <br />wildfires. Wildfire hazards, including wildfire intensity and rate of spread, could be somewhat reduced <br />through implementation of the Project. The PEIR evaluated the potential for CalVTP treatments to produce <br />GHG emissions and determined the impact to be potentially significant and unavoidable. This was found <br />to be the cause because although SPRs and MMs are in place, cumulative emissions from activities like <br />mechanical vegetation removal, prescribed burning, and equipment operation may still surpass thresholds <br />established by climate action policies. No feasible mitigation that could fully offset or eliminate these <br />emissions was identified. <br />This impact falls within the scope of the PEIR, as the Project’s proposed activities—including the type of <br />equipment used, duration of operations, and the objective to reduce wildfire risk and associated GHG <br />emissions—align with those evaluated in the PEIR. MM GHG-2 would be implemented to reduce GHG <br />emissions from pile burning by targeting burns when fuel moisture is higher, minimizing the total area <br />burned through mosaic patterns, leaving large fuels unburned, and timing burns to occur before the <br />emergence of new fuels. Despite the implementation of this measure, treatment activities would <br />contribute to annual GHG emissions generated under the CalVTP, and this impact would fall within the <br />finding of potentially significant and unavoidable, as identified in the PEIR. Methods for reducing GHG <br />emissions from burns would be integrated into SPR AQ-3 (Burn Plan) as described in MM GHG-2. <br />The inclusion of approximately 93 acres of land that is outside the CalVTP treatable landscape in the <br />proposed treatment area constitutes a change to the geographic extent presented in the PEIR, and the <br />added acreage would not expand the total annual acreage of 250,000 acres per year proposed for <br />treatment under the PEIR. However, GHG emissions and associated climate change impacts are global in <br />nature and are not contained within the boundary of the treatable areas. Therefore, the GHG impact is <br />also the same, as described above. This determination is consistent with the PEIR and would not constitute <br />a substantially more severe significant impact than what was covered in the PEIR. <br />4.7.1.3. New Impacts Related to GHG Emissions <br />The proposed treatment is consistent with the treatment types and activities considered in the CalVTP <br />PEIR. The project proponent has considered the site-specific characteristics of the proposed treatments <br />and determined they are consistent with the applicable regulatory and environmental conditions <br />presented in the CalVTP PEIR (Section 3.8.1, Regulatory Setting, and Section 3.8.2, Environmental Setting, <br />in Volume II of the Final PEIR).