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ARROYO LAGO RESIDENTIAL PROJECT ADDENDUM FCS 119 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480036/Addendum/21480036 Arroyo Lago Residential Project Addendum.docx According to the GHG analysis prepared for the County Project, although it would not result in any wasteful, inefficient, or unnecessary energy use, the County Project would not fully meet Criterion A due to its reliance on natural gas and inability to achieve the required VMT reduction. It also would not meet Criterion B, as it would not be consistent with a qualified Climate Action Plan (CAP) because the County’s CAP would not apply for streamlining due to its use of the 2020 GHG targets instead of the 2030 GHG targets. As detailed more fully therein, the Prior FEIR evaluated consistency with the California Air Resources Board (ARB) Scoping Plan, Plan Bay Area 2050, and the Bay Area Air District 2017 Clean Air Plan. Although the County Project includes some measures to reduce emissions to the extent feasible (e.g., traffic calming and bicycle infrastructure under MM TRANS-2), it does not fully align with the design elements required under the Bay Area Air District’s CEQA Guidelines, as described above. Therefore, the Prior FEIR concluded there would be a significant impact in this regard. MM GHG-1 and MM GHG-2 require pre-wiring for future all-electric retrofits and the purchase of carbon offsets to mitigate emissions from natural gas use. However, even with these measures, the Prior FEIR determined that the County Project would still exceed the Bay Area Air District thresholds because it would not demonstrate a 15 percent VMT reduction. Under Alternative 2, GHG emissions would be slightly reduced due to the smaller development footprint, but the residential component would still involve the use of natural gas and exceed the City’s per capita GHG threshold, resulting in a significant and unavoidable impact. The reduction in GHG emissions under Alternative 2 would not be sufficient to avoid a significant impact. (Draft EIR, pp. 6-15–6-16). Therefore, the Prior FEIR concluded that impacts would be significant and unavoidable. (Draft EIR, pp. 3.7-22, 6-15–6-16). Proposed Project Analysis and Conclusion Similar to the County Project, the proposed project would be required to comply with the applicable Title 24 Energy Efficiency Standards and CALGreen requirements—for example, and among others, EV charging infrastructure and solar requirements as adopted by Municipal Code Chapter 20.08. The City’s CAP 2.0 is considered a qualified GHG reduction strategy pursuant to CEQA Guidelines Section 15183.5(b). Therefore, for purposes of this Addendum, the proposed project is analyzed pursuant to the Bay Area Air District’s current GHG significance thresholds under Criterion B: consistency with a local GHG reduction strategy that meets the criteria under CEQA Guidelines Section 15183.5(b). GHG emissions associated with the development of the proposed project would occur over the short- term from construction activities, consisting primarily of emissions from equipment exhaust and worker and vendor trips. There would also be long-term operational emissions associated with vehicular traffic within the project vicinity, energy and water usage, and solid waste disposal. The proposed project would be largely the same as the County Project, only with fewer proposed dwelling units and a substantial reduction in the nature and scope of off-site improvements. As such, the proposed project would result in a similar, if not lower, amount of GHG emissions during construction and operation.