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Home My WebLink AboutSDP 2019-0005; BMW CARLSBAD; GREENHOUSE GAS STUDY; 2019-07-01■ fl RINCON CONSULTANTS, INC. Environmental Scientists I Planners I Engineers rinconconsultants.com Greenhouse Gas Study prepared for Spare+ LLC 800 Lambert Drive NE, Suite B Lambert, Georgia 30324 prepared by Rincon Consultants, Inc. 2215 Faraday Avenue, Suite A Carlsbad, California 92008 July 2019 R~c~=,vED JUL 2 F 20t9 C 1 Y OF CARL.SBA'.) . --'~.\.. ' .:, __,,,., .~.v. .. .. ... .. .. -.. .. • .. -.. ----.. .. • • • .. .. "" • .. - Table of Contents Table of Contents 1 Project Description ............................................................................................................ 1 1.1 Purpose .................................................................................................................. l 1.2 Project Summary .................................................................................................... 1 2 Background ........................................................................................................................ 3 2.1 Climate Change and Greenhouse Gases ................................................................ 3 2.2 Greenhouse Gas Emissions lnventory .................................................................... 4 2.3 Potential Effects of Climate Change ....................................................................... 5 2.4 Regulatory Setting .................................................................................................. 7 3 lmpactAnalysis ................................................................................................................ 15 3.1 Methodology ........................................................................................................ 15 3.2 Significance Thresholds ........................................................................................ 18 3.3 Project Impacts .................................................................................................... 20 4 Conclusion ........................................................................................................................ 22 5 References ....................................................................................................................... 23 Tables Table 1 Table 2 Table 3 Appendices City of Carlsbad's Projected Emissions .......................................................... 13 Estimated Construction Emissions ................................................................ 20 Combined Annual Project Emissions ............................................................. 21 Appendix A CalEEMod Air Quality and Greenhouse Gas Model Worksheets: Project Appendix B CalEEMod Air Quality and Greenhouse Gas Model Worksheets: Existing Use Appendix C Mobile N20 Emissions: Project Appendix D Mobile N20 Emissions: Existing Use Greenhouse Gas Study -Spare+ LLC -BMW of Carlsbad ... .. "ill .. ... .. ... .. • .. .. - • .. "' • .. This page intentionally left blank . .. • • • • .. .. .. • .. .. .. .. • .. .. .. ii - • ... .. "' ... ... .. ... "' .. .. - -.. .. .. .. • .. ... Project Description 1 Project Description 1.1 Purpose This study analyzes the potential greenhouse gas (GHG) emission impacts and the corresponding impact to global climate change associated with the proposed BMW of Carlsbad Project located in Carlsbad, California and evaluates the project's consistency with the City of Carlsbad General Plan, City of Carlsbad Climate Action Plan (CAP), and state greenhouse gas (GHG) regulations. This report has been prepared by Rincon Consultants, Inc. for use by the City of Carlsbad in support of the environmental documentation being prepared pursuant to the California Environmental Quality Act (CEQA). This study describes the proposed project, global climate change, GHGs, and the current regulatory framework; quantifies GHG emissions for the proposed project; compares modeled project emissions to the City's quantitative thresholds and existing baseline emissions; and discusses the project's consistency with both State and local legislation, including the City's CAP. This analysis concludes that net project GHG emissions resulting from the completion of the proposed project would not exceed the 900 metric ton (MT) screening threshold established by the City of Carlsbad CAP and would comply with applicable City ordinances; therefore, the project would be consistent with the City's CAP. 1.2 Project Summary Project Location The project site is a 3.71-acre (161,503 square foot) lot located at the intersection of Car Country Drive and Auto Center Court, directly south of Cannon Road, in Carlsbad, California (Assessor's Parcel Number 211-080-11-00). Project Description The proposed project involves construction of a four-story building and associated parking for use by a car dealership. The proposed building would include two stories for service, parts, and showroom uses with a combined gross floor area of 68,941 square feet and a two-story, 388-space rooftop parking structure. The project would also include a landscaped, surface parking lot with 99 parking spaces. To accommodate the proposed project, two existing single-story buildings and an associated parking lot that currently support various automotive service operators, including a car rental company, vehicle service and smog check centers, and an auto glass supplier would be demolished. To comply with the City of Carlsbad's photovoltaic (PV) Ordinance CS-347, an approximately 103- kilowatt (kW) direct current capacity PV array would be required to generate energy on-site, which would produce an estimated 152,646-kilowatt hours (kWh) of electricity (U.S. Department of Energy 2003, Solar Power Rocks 2018). The capacity of the PV array is consistent with the City's CAP Checklist requirement of lSkW per 10,000 square feet for the proposed 68,941-square foot gross building area. In addition, energy and lighting use for the building and parking areas would meet 2019 CalGreen Building Standards. Furthermore, the public parking areas would also include fifteen Greenhouse Gas Study "" ... -.. -.. .. ... ... ... .. .. ... .. .. • .. .. -.. .. ... .. .. -... - Spare+ LLC BMW of Carlsbad electric vehicle (EV) charging spaces and fourteen additional pre-wired, EV-ready spaces in compliance with City Ordinance CS-349, adopted in April 2019. Demolition and Construction Demolition and construction activities are anticipated to occur over the course of 15 months from January 2020 through March 2021. It is anticipated that the construction period for the proposed project would require approximately four months for demolition, site preparation, grading, utility installation and paving and approximately 11 months for building construction. The project would require export of approximately 4,244 cubic yards (CY) of soil and import of approximately 376 CY. Soil import would occur over approximately ten days . 2 .. .. .. • - • - .. .. -- • - • • -.. - ---.. - -- - .. Background 2 Background This section analyzes GHG emissions associated with the project and potential impacts related to climate change. 2.1 Climate Change and Greenhouse Gases Climate change is the observed increase in the average temperature of Earth's atmosphere and oceans along with other substantial changes in climate (such as wind patterns, precipitation, and storms) over an extended period of time. The term "climate change" is often used interchangeably with the term "global warming", but "climate change" is preferred to "global warming" because it helps convey that there are other changes in addition to rising temperatures. The baseline against which these changes are measured originates in historical records identifying temperature changes that have occurred in the past, such as during previous ice ages. The global climate is continuously changing, as evidenced by repeated episodes of substantial warming and cooling documented in the geologic record. The rate of change has typically been incremental, with warming or cooling trends occurring over the course of thousands of years. The past 10,000 years have been marked by a period of incremental warming, as glaciers have steadily retreated across the globe. However, scientists have observed acceleration in the rate of warming during the past 150 years. Per the United Nations Intergovernmental Panel on Climate Change (IPCC), the understanding of anthropogenic warming and cooling influences on climate has led to a high confidence (95 percent or greater chance) that the global average net effect of human activities has been the dominant cause of warming since the mid-20th century (IPCC 2014) . GHGs are gases that absorb and re-emit infrared radiation in the atmosphere. The gases that are widely seen as the principal contributors to human-induced climate change include carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), fluorinated gases such as hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs), and sulfur hexafluoride (SF&). Water vapor is excluded from the list of GHGs because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation. GHGs are emitted by both natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities from human activities. Emissions of CO2 are largely by-products of fossil fuel combustion, whereas CH4 results from off-gassing associated with agricultural practices and landfills. Observations of CO2 concentrations, globally-averaged temperatures, and sea level rise are generally well within the range of earlier IPCC projections. The recently observed increases in CH4 and N2O concentrations are smaller than those assumed in the scenarios in the previous assessments. Each IPCC assessment has used new projections of future climate change that have become more detailed as the models have become more advanced. Man-made GHGs, many of which have greater heat-absorption potential than CO2, include fluorinated gases and SF& (United States Environmental Protection Agency [U.S. EPA] 2019). Different types of GHGs have varying global warming potentials (GWPs). The GWP of a GHG is the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a common reference gas (CO2) is used to relate the amount of heat absorbed to the amount of the gas emissions, referred to as "carbon dioxide equivalent" (CO2e), and is the amount of a GHG emitted multiplied by its GWP. CO2 has a Greenhouse Gas Study 3 - • • .. • • -.. - - -- • .. • -.. .. .. .. Spare+ LLC BMW of Carlsbad 100-year GWP of one. By contrast, CH4 has a GWP of 25, meaning its global warming effect is 25 times greater than CO2 on a molecule per molecule basis (IPCC 2007). The accumulation of GHGs in the atmosphere regulates the earth's temperature. Without the natural heat trapping effect of GHGs, Earth's surface would be about 34° C cooler (California Environmental Protection Agency [Cal EPA] 2006). However, it is believed that emissions from human activities, particularly the consumption of fossil fuels for electricity production and transportation, have elevated the concentration of these gases in the atmosphere beyond the level of naturally occurring concentrations. Scientific modeling predicts that continued GHG emissions at or above current rates would induce more extreme climate changes during the 2l5t century than were observed during the 20th century . Some of the potential impacts in California of global warming may include loss of snow pack, sea level rise, more extreme heat days per year, more high ozone days, more large forest fires, and more drought years (State of California 2018). While these potential impacts identify the possible effects of climate change at a global and potentially statewide level, in general, scientific modeling tools are currently unable to predict what impacts would occur locally . 2.2 Greenhouse Gas Emissions Inventory Worldwide anthropogenic emissions of GHG were approximately 46,000 million metric tons (MMT, or gigatonne) of CO2e in 2010 (IPCC 2014). CO2 emissions from fossil fuel combustion and industrial processes contributed about 65 percent of total emissions in 2010. Of anthropogenic GHGs, CO2 was the most abundant accounting for 76 percent of total 2010 emissions. CH4 emissions accounted for 16 percent of the 2010 total, while N2O and fluorinated gases account for 6 and 2 percent respectively (IPCC 2014). Total United States GHG emissions were 6,456.7 million metric tons (MMT or gigatonnes) of CO2e in 2017 (USEPA 2019). Total United States emissions have increased by 1.3 percent since 1990; emissions decreased by 0.5 percent from 2016 to 2017 (USEPA 2019). The decrease from 2016 to 2017 was a result of multiple factors, including: (1) a continued shift from coal to natural gas and other non-fossil energy sources in the electric power sector and (2) milder weather in 2017 resulting in overall decreased electricity usage (USEPA 2019). Since 1990, U.S. emissions have increased at an average annual rate of 0.05 percent. In 2017, the industrial and transportation end-use sectors accounted for 30 percent and 29 percent, respectively, of GHG emissions (with electricity-related emissions distributed). Meanwhile, the residential and commercial end-use sectors accounted for 15 percent and 16 percent of GHG emissions, respectively (USEPA 2019). Based on CARB's California Greenhouse Gas Inventory for 2000-2016, California produced 429.4 MMT of CO2e in 2016 (CARB 2018). The major source of GHGs in California is associated with transportation, contributing 41 percent of the state's total GHG emissions. The industrial sector is the second largest source, contributing 23 percent of the state's GHG emissions, and electric power accounted for approximately 16 percent (CARB 2018). California emissions are due in part to its large size and large population compared to other states. However, a factor that reduces California's per capita fuel use and GHG emissions, as compared to other states, is its relatively mild climate. In 2016, the State of California achieved its 2020 GHG emission reduction targets as emissions fell below 431 MMT of CO2e (CARB 2018). The annual 2030 statewide target emissions level is 260 MMT of CO2e (CARB 2017). With implementation of the 2017 Scoping Plan, regulated GHG emissions are projected to decline to 260 MMT of CO2e per year by 2030. Per Executive Order (EO) B-55-18, the statewide goal for 2045 is to achieve carbon neutrality and maintain net negative emissions 4 • --.. - --.. .. -.. .. • .. - • -- -.. • -... - - Background thereafter. This goal supersedes the 2050 goal of an 80 percent reduction in GHG emissions below 1990 levels established by EO S-3-05, and CARB has been tasked with including a pathway toward the EO B-55-18 carbon neutrality goal in the next Scoping Plan update. 2.3 Potential Effects of Climate Change Globally, climate change has the potential to affect numerous environmental resources though potential impacts related to future air temperatures and precipitation patterns. Scientific modeling predicts that continued GHG emissions at or above current rates would induce more extreme climate changes during the 21st century than were observed during the 20th century. Long-term trends have found that each of the past three decades has been warmer than all the previous decades in the instrumental record, and the decade from 2000 through 2010 has been the warmest. The observed global mean surface temperature (GMST) for the decade from 2006 to 2015 was approximately 0.87°C (0.75°C to 0.99°C) higher than the average GMST over the period from 1850 to 1900. Furthermore, several independently analyzed data records of global and regional Land- Surface Air Temperature (LSAT) obtained from station observations are in agreement that LSAT as well as sea surface temperatures have increased. Due to past and current activities, anthropogenic GHG emissions are increasing global mean surface temperature at a rate of 0.2°C per decade. In addition to these findings, there are identifiable signs that global warming is currently taking place, including substantial ice loss in the Arctic over the past two decades (IPCC 2014 and 2018). According to California's Fourth Climate Change Assessment, statewide temperatures from 1986 to 2016 were approximately 1 °F to 2°F higher than those recorded from 1901 to 1960. Potential impacts of climate change in California may include loss in water supply from snow pack, sea level rise, more extreme heat days per year, more large forest fires, and more drought years (State of California 2018). While there is growing scientific consensus about the possible effects of climate change at a global and statewide level, current scientific modeling tools are unable to predict what local impacts may occur with a similar degree of accuracy. In addition to statewide projections, California's Fourth Climate Change Assessment includes regional reports that summarize climate impacts and adaptation solutions for nine regions of the state as well as regionally-specific climate change case studies (State of California 2018). Below is a summary of some of the potential effects that could be experienced in California as a result of climate change . Air Quality Higher temperatures, which are conducive to air pollution formation, could worsen air quality in California. Climate change may increase the concentration of ground-level ozone, but the magnitude of the effect, and therefore its indirect effects, are uncertain. As temperatures have increased in recent years, the area burned by wildfires throughout the state has increased, and wildfires have been occurring at higher elevations in the Sierra Nevada Mountains (State of California 2018). If higher temperatures continue to be accompanied by an increase in the incidence and extent of large wildfires, air quality would worsen. However, if higher temperatures are accompanied by wetter, rather than drier conditions, the rains would tend to temporarily clear the air of particulate pollution and reduce the incidence of large wildfires, thereby ameliorating the pollution associated with wildfires. Additionally, severe heat accompanied by drier conditions and poor air quality could increase the number of heat-related deaths, illnesses, and asthma attacks throughout the state (California Natural Resources Agency 2009) . Greenhouse Gas Study 5 .. .. .. "' -.. .. - • - • .. • -• • • • .. - • • • • .. • -- Spare+ LLC BMW of Carlsbad Water Supply Analysis of paleoclimatic data (such as tree-ring reconstructions of stream flow and precipitation) indicates a history of naturally and widely varying hydrologic conditions in California and the west, including a pattern of recurring and extended droughts. Uncertainty remains with respect to the overall impact of climate change on future precipitation trends and water supplies in California. For example, many southern California cities have experienced their lowest recorded annual precipitation twice within the past decade; however, in a span of only two years, Los Angeles experienced both its driest and wettest years on record (California Department of Water Resources [DWR] 2008). This uncertainty regarding future precipitation trends complicates the analysis of future water demand, especially where the relationship between climate change and its potential effect on water demand is not well understood. However, the average early spring snowpack in the western United States, including the Sierra Nevada Mountains, decreased by about 10 percent during the last century. During the same period, sea level rose over 5.9 inches along the central and southern California coast (State of California 2018). The Sierra snowpack provides the majority of California's water supply by accumulating snow during the state's wet winters and releasing it slowly during the state's dry springs and summers. A warmer climate is predicted to reduce the fraction of precipitation falling as snow and result in less snowfall at lower elevations, thereby reducing the total snowpack (DWR 2008; State of California 2018). The State of California projects that average spring snowpack in the Sierra Nevada and other mountain catchments in central and northern California will decline by approximately 66 percent from its historical average by 2050 (State of California 2018) . Hydrology and Sea Level Rise As discussed above, climate change could potentially affect the amount of snowfall, rainfall, and snow pack; the intensity and frequency of storms; flood hydrographs (flash floods, rain or snow events, coincidental high tide and high runoff events); sea level rise and coastal flooding; coastal erosion; and the potential for salt water intrusion. Climate change has the potential to induce substantial sea level rise in the coming century (State of California 2018). The rising sea level increases the likelihood and risk of flooding. The rate of increase of global mean sea levels over the 2001-2010 decade, as observed by satellites, ocean buoys and land gauges, was approximately 3.2 mm per year, which is double the observed 20th century trend of 1.6 mm per year (World Meteorological Organization [WMO] 2013). As a result, global mean sea levels averaged over the last decade were about 8 inches higher than those of 1880 (WMO 2013). Sea levels are rising faster now than in the previous two millennia, and the rise is expected to accelerate, even with robust GHG emission control measures. The most recent IPCC report predicts a mean sea-level rise of 10 to 37 inches by 2100 (IPCC 2018). A rise in sea levels could completely erode 31 to 67 percent of southern California beaches, result in flooding of approximately 370 miles of coastal highways during 100-year storm events, jeopardize California's water supply due to salt water intrusion, and induce groundwater flooding and/or exposure of buried infrastructure (State of California 2018). In addition, increased CO2 emissions can cause oceans to acidify due to the carbonic acid it forms . Increased storm intensity and frequency could affect the ability of flood-control facilities, including levees, to handle storm events . Agriculture California has a $50 billion annual agricultural industry that produces over a third of the country's vegetables and two-thirds of the country's fruits and nuts (California Department of Food and 6 .. .. .. • • .. - • • • • - - .. • • • • - • • .. --- .. Background Agriculture 2018). Higher CO2 levels can stimulate plant production and increase plant water-use efficiency. However, if temperatures rise and drier conditions prevail, certain regions of agricultural production could experience water shortages of up to 16 percent; water demand could increase as hotter conditions lead to the loss of soil moisture; crop-yield could be threatened by water-induced stress and extreme heat waves; and plants may be susceptible to new and changing pest and disease outbreaks (State of California 2018). In addition, temperature increases could change the time of year certain crops, such as wine grapes, bloom or ripen, and thereby affect their quality (California Climate Change Center 2006) . Ecosystems and Wildlife Climate change and the potential resulting changes in weather patterns could have ecological effects on a global and local scale. Increasing concentrations of GHGs are likely to accelerate the rate of climate change. Scientists project that the annual average maximum daily temperatures in California could rise by 4.4 to 5.8°F in the next 50 years and by 5.6 to 8.8°F in the next century (State of California 2018). Soil moisture is likely to decline in many regions, and intense rainstorms are likely to become more frequent. Rising temperatures could have four major impacts on plants and animals related to (1) timing of ecological events; (2) geographic distribution and range; (3) species' composition and the incidence of nonnative species within communities; and (4) ecosystem processes, such as carbon cycling and storage (Parmesan 2006; State of California 2018). 2.4 Regulatory Setting The following regulations address both climate change and GHG emissions . California Regulations The State of California considers GHG emissions and the impacts of climate change to be a serious threat to the public health, environment, economic well-being, and natural resources of California and has taken an aggressive stance to mitigate the State's impact on climate change through the adoption of policies and legislation. CARB is responsible for the coordination and oversight of state and local air pollution control programs in California. California has a numerous regulations aimed at reducing the state's GHG emissions. Some of the major initiatives are summarized below. California Advanced Clean Cars Program Assembly Bill (AB) 1493 (2002), California's Advanced Clean Cars program (referred to as "Pavley"), requires CARB to develop and adopt regulations to achieve "the maximum feasible and cost- effective reduction of GHG emissions from motor vehicles." On June 30, 2009, USE PA granted the waiver of Clean Air Act preemption to California for its GHG emission standards for motor vehicles beginning with the 2009 model year. Pavley I regulates model years from 2009 to 2016 and Pavley II, which is now referred to as "LEV (Low Emission Vehicle) Ill GHG" regulates model years from 2017 to 2025. The Advanced Clean Cars program coordinates the goals of the Low Emissions Vehicles (LEV), Zero Emissions Vehicles (ZEV), and Clean Fuels Outlet programs, and would provide major reductions in GHG emissions. By 2025, when the rules will be fully implemented, new automobiles will emit 34 percent fewer GHGs and 75 percent fewer smog-forming emissions from their model year 2016 levels (CARB 2011). Greenhouse Gas Study 7 .. • .. --.. • • • • • • • • -- .. -- .. • • -- -- Spare+ LLC BMW of Carlsbad Assembly Bill 32 California's major initiative for reducing GHG emissions is outlined in Assembly Bill (AB) 32, the "California Global Warming Solutions Act of 2006," which was signed into law in 2006. AB 32 codifies the statewide goal of reducing GHG emissions to 1990 levels by 2020 and requires CARB to prepare a Scoping Plan that outlines the main State strategies for reducing GHGs to meet the 2020 deadline. In addition, AB 32 requires CARB to adopt regulations to require reporting and verification of statewide GHG emissions. Based on this guidance, CARB approved a 1990 statewide GHG level and 2020 limit of 427 MMT CO2e. The Scoping Plan was approved by CARB on December 11, 2008 and included measures to address GHG emission reduction strategies related to energy efficiency, water use, and recycling and solid waste, among other measures. Many of the GHG reduction measures included in the Scoping Plan (e.g., Low Carbon Fuel Standard, Advanced Clean Car standards, and Cap-and-Trade) have been adopted since approval of the Scoping Plan . In May 2014, CARB approved the first update to the AB 32 Scoping Plan. The 2013 Scoping Plan update defined CARB's climate change priorities for the next five years and set the groundwork to reach post-2020 statewide goals. The update highlighted California's progress toward meeting the "near-term" 2020 GHG emission reduction goals defined in the original Scoping Plan. It also evaluated how to align the State's longer-term GHG reduction strategies with other State policy priorities, including those for water, waste, natural resources, clean energy, transportation, and land use (CARB 2014) . Senate Bill 37 5 Senate Bill (SB) 375, signed in August 2008, enhances the State's ability to reach AB 32 goals by directing CARB to develop regional GHG emission reduction targets to be achieved from passenger vehicles for 2020 and 2035. In addition, SB 375 directs each of the state's 18 major Metropolitan Planning Organizations (MPO) to prepare a "sustainable communities strategy" (SCS) that contains a growth strategy to meet these emission targets for inclusion in the Regional Transportation Plan (RTP). On March 22, 2018, CARB adopted updated regional targets for reducing GHG emissions from 2005 levels by 2020 and 2035. SCAG was assigned targets of an 8 percent reduction in GHGs from transportation sources by 2020 and a 19 percent reduction in GHGs from transportation sources by 2035. In the SCAG region, SB 375 also provides the option for the coordinated development of subregional plans by the subregional councils of governments and the county transportation commissions to meet SB 375 requirements . Senate Bill 97 SB 97, signed in August 2007, acknowledges that climate change is an environmental issue that requires analysis in California Environmental Quality Act (CEQA) documents. In March 2010, the California Natural Resources Agency (Resources Agency) adopted amendments to the State CEQA Guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions. The adopted guidelines give lead agencies the discretion to set quantitative or qualitative thresholds for the assessment and mitigation of GHG and climate change impacts . Senate Bill 1383 Adopted in September 2016, SB 1383 requires the CARB to approve and begin implementing a comprehensive strategy to reduce emissions of short-lived climate pollutants. The bill requires the strategy to achieve the following reduction targets by 2030: 8 .. .. - • .. .. • -- - • ... .. • • - .. • • • • -- Background ■ Methane: 40 percent below 2013 levels ■ Hydrofluorocarbons: 40 percent below 2013 levels ■ Anthropogenic black carbon: 50 percent below 2013 levels The bill also requires the California Department of Resources Recycling and Recovery, in consultation with CARB, to adopt regulations that achieve specified targets for reducing organic waste in landfills . Senate Bill 32 On September 8, 2016, the governor signed Senate Bill 32 (SB 32) into law, extending AB 32 by requiring the State to further reduce GHGs to 40 percent below 1990 levels by 2030 (the other provisions of AB 32 remain unchanged). On December 14, 2017, CARB adopted the 2017 Scoping Plan, which provides a framework for achieving the 2030 target. The 2017 Scoping Plan relies on the continuation and expansion of existing policies and regulations, such as the Cap-and-Trade Program, as well as implementation of recently adopted policies and policies, such as SB 350 and SB 1383 (see below). The 2017 Scoping Plan also puts an increased emphasis on innovation, adoption of existing technology, and strategic investment to support its strategies. As with the 2013 Scoping Plan Update, the 2017 Scoping Plan does not provide project-level thresholds for land use development. Instead, it recommends that local governments adopt policies and locally-appropriate quantitative thresholds consistent with statewide per capita goals of six metric tons (MT) CO2e by 2030 and two MT CO2e by 2050 (CARB 2017). As stated in the 2017 Scoping Plan, these goals may be appropriate for plan-level analyses (city, county, subregional, or regional level), but not for specific individual projects because they include all emissions sectors in the state (CARB 2017). Senate Bill 100 Adopted on September 10, 2018, SB 100 supports the reduction of GHG emissions from the electricity sector by accelerating the state's Renewables Portfolio Standard (RPS) Program, which was last updated by SB 350 in 2015. SB 100 requires electricity providers to increase procurement from eligible renewable energy resources to 33 percent of total retail sales by 2020, 44 percent by 2024, 60 percent by 2030, and 100 percent by 2045. Executive Order B-55-18 On September 10, 2018, the governor issued Executive Order B-55-18, which established a new statewide goal of achieving carbon neutrality by 2045 and maintaining net negative emissions thereafter. This goal is in addition to the existing statewide GHG reduction targets established by SB 375, SB 32, SB 1383, and SB 100. EO B-55-18 also tasks CARB with including a pathway toward the EO B-55-18 carbon neutrality goal in the next Scoping Plan update . California Environmental Quality Act Pursuant to the requirements of SB 97, the Resources Agency has adopted amendments to the State CEQA Guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions. The adopted CEQA Guidelines provide general regulatory guidance on the analysis and mitigation of GHG emissions in CEQA documents, while giving lead agencies the discretion to set quantitative or qualitative thresholds for the assessment and mitigation of GHGs and climate change impacts. To date, a variety of air districts have adopted quantitative significance thresholds for GHGs . Greenhouse Gas Study 9 .. • • • - • • .. -- • • .. • .. .. .. • • - • ---- Spare+ LLC BMW of Carlsbad For more information on Senate and Assembly bills, Executive Orders, and reports discussed above, and to view reports and research referenced above, please refer to www.climatechange.ca.gov and www.arb.ca.gov/cc/cc.htm. Regional Regulations SANDAG Climate Action Strategy The San Diego Association of Governments (SAN DAG) Climate Action Strategy serves as a guide to help policymakers address climate change as they make decisions to meet the needs of the growing regional population, maintain and enhance quality of life, and promote economic stability. The policy measures are intended to be a list of potential options for consideration as local governments update their general plans and other community plans. These measures are not requirements by SAN DAG, local governments, or any other entity, and it is the discretion of each agency to decide whether and how to implement the measures listed in the Climate Action Strategy. SANDAG 2009 Son Diego Regional Energy Strategy The Regional Energy Strategy (RES) is an integral part of the San Diego Regional Comprehensive Plan and contains a set of public policies, strategies and action plans to promote more sustainable growth for the San Diego region. The following goals are set forth by the RES: ■ Renewable Energy. Support the development of renewable energy resources to meet or exceed a 33% RPS by 2020 and a 45% RPS by 2030. ■ Distributed Generation. Increase the total amount of clean distributed generation (renewable and non-renewable) to reduce peak demand and diversify electricity resources in the San Diego region. ■ Energy and Water. Reduce water-related energy use. ■ Peak Demand. Implement cost-effective steps and incentives to utilize demand response and energy efficiency measures to reduce peak demand . ■ Transportation Fuels. Substantially increase the deployment of alternative transportation fuels and vehicles . Local Plans and Regulations Sustainable Energy Moster Pion In December 2008, the City of Carlsbad released its Sustainable Energy Master Plan, a report on potential renewable energy sources and measures to reduce power consumption. This report evaluated a variety of energy efficiency and reduction measures including automated meter readings to monitor water meters and reduce operating costs, off-peak water pumping to lower power costs, and variable speed motors to increase efficiency of heating, ventilation, and air conditioning (HVAC) systems and water pumps. The report also evaluated green roofs to reduce indoor building temperatures and associated GHG emissions from indoor climate control systems as well as solar water heating systems and tankless water heating systems to reduce energy consumption. Furthermore, the Master Plan addressed hybrid and electric vehicles, energy efficient chillers, LEED green building standards, light-emitting diode (LED) traffic signals and interconnection, induction and LED streetlights, and energy management systems. 10 .. .. .. ... .. -- • -.. • .. .. .. .. .. -.. -.. -.. • .. -.. -- Background Carlsbad Building Code 18.18 Solar Energy Code The City of Carlsbad adopted the Uniform Solar Energy Code, 2015 Edition as a baseline solar energy code for the City. The 2015 Uniform Solar Energy Code provides provisions for a safe and functional solar energy system with minimum regulations. It applies to the erection, installation, alteration, repair, replacement, addition to, use, or maintenance of solar energy systems . Carlsbad Building Code 18.30 Energy Conservation Regulations The City of Carlsbad adopted the California Energy Code, 2016 Edition as a baseline energy code for the City. Carlsbad Building Code Section 18.30.040 requires all new residential units to include plumbing designed to allow for later installation of a system which utilizes solar energy as the primary means of heating domestic potable water. City of Carlsbad Climate Change Initiatives The City of Carlsbad recognizes that government operations and community activities contribute to GHG emissions, which may adversely affect city businesses and residents. The City also understands that local government plays a key role in both reducing GHG emissions and adapting to the potential effects of climate change. The City has taken a proactive approach to creating a sustainable and healthy quality of life in Carlsbad by balancing the social, economic, and environmental needs of the community. The City's efforts toward environmental sustainability include the efficient use of non- renewable resources, stewardship of natural and constructed open spaces, development of drought-resistant water supplies, reduction in the city's waste stream, and measures to promote clean air and water. Specific examples of the City's sustainability efforts include: • Vehicle Fleet Operations. Purchase of hybrid vehicle . • Renewable Energy. Construction of a hydroelectric power project at Maerkle Reservoir . • Water Conservation. Implementation of conservation programs to reduce water demand and dependency on imported water supplies and adoption of a drought response plan and water conservation program through Carlsbad Municipal Water District Ordinance No. 44 in January 2009 . • High Efficiency Streetlights. Replacement of more than 7,000 high-pressure sodium street-lights throughout Carlsbad with high-efficiency induction lights that use 60 percent less electricity than the old lights. • Energy Management. Participation in the Sustainable Region Program with SANDAG, California Center for Sustainable Energy (CCSE), and San Diego Gas & Electric (SDG&E) to develop energy management plans and implement cost-saving energy measures for municipal facilities. The City was the initial agency collaborating with SAN DAG, CCSE, and SDG&E when the Sustainable Region Program Pilot launched in 2005. Today, it is one of five agencies involved in the program to identify energy management road maps and implement cost-saving energy measures for their particular agencies. • Waste Reduction and Recycling. Development of a green purchasing policy . • Energy Partnerships. At the state level, collaboration with the Attorney General's office to effect legislation that would advance the California Solar Initiative and other solar financing options. At the local level, partnership with SDG&E to assist residents in energy audits and participation in demand response programs that commit the city to reducing its electric use during periods of peak demand such as hot summer days . Greenhouse Gas Study 11 .. .. -- -.. .. - -- .. - .. ... ---- .. --- Spare+ LLC BMW of Carlsbad ■ Climate Action Planning. Completion of a 2005 GHG emissions baseline inventory for municipal operations (of which the City has direct control) and community activities (excluding the airport and power plant). The City utilized this baseline to identify GHG emission sources and opportunities to improve operations not only to reduce GHG emissions, but also to invest in more energy efficiency programs and partnerships. □ Examples of the City's actions to reduce energy consumption include 1) installing complete HVAC systems in all City-owned buildings occupied by at least 15 people in order to establish automatic and manual climate controls and rezone the control center and 2) measuring energy consumption by use in order to monitor energy spikes at City facilities and adjust energy load settings. ■ Climate Adaptation Planning. The City identified three primary effects of a changing climate that are particular threats to Carlsbad: drought, fire, and rising sea level. Some of the City's current efforts to adapt to these effects of climate change include, but are not limited to, actively pursuing desalination opportunities, investing in a recycled water system that provides 20 percent of the city's water supply, requiring Class I fire-resistant roofs, enforcing a strict fire code and fuel-modification zones around development, restricting development within the 100- year floodplain, and identifying areas of the city that could be threatened by sea level rise. Carlsbad General Plan The City of Carlsbad General Plan was adopted in September 2015 with a development horizon of 2035. Its purpose is to guide decisions "related to protecting, enhancing, and providing those things the community values most, such as open space, habitat conservation, beach preservation, arts and community character" (City of Carlsbad 2015a). The General Plan's Land Use and Community Design Element intends to ensure that land use planning reflects changing community demographics and promotes the City's position as a center for innovation, employment and commerce. It also intends to promote sustainability and maintain a livable, coastal feel by incorporating density standards and encouraging pedestrian-oriented development and mixed-use areas. The City's General Plan was adopted in conjunction with the City's CAP. The CAP, further described below, develops a strategy for citywide GHG reductions that reflect expected land uses established in the General Plan and thus provides a legally enforceable document for mitigating GHGs from all activities anticipated by the General Plan. All developments constructed within the zones and planning areas noted in the General Plan would be subject to the established Climate Action Plan guidelines, specifically the City of Carlsbad CAP Project Review Checklist . Carlsbad Climate Action Plan As discussed above, the City of Carlsbad adopted its CAP in September 2015 in conjunction with its General Plan (City of Carlsbad 2015b). The CAP outlines the City's goals for GHG reductions, which are consistent with AB 32 and SB 32. By calculating a "modified baseline forecast," the City can compare expected GHG emissions in 2020 and beyond to the State-mandated emissions targets. The modified baseline is the City's current emissions level adjusted to include both population growth and state-level reductions. The difference between the modified baseline and the emissions target is referred to as the "emissions gap." The CAP is intended to eliminate this gap and thus meet the requirements of AB 32 and SB 32. The City of Carlsbad performed an inventory of 2005 GHG emissions, which it then used to develop a "modified baseline" forecast. The City estimated 1990 GHG emission levels by reducing 12 ... ... ... - • • ... .. .. -.. • • .. • - -.. .. --... ----- Background inventoried 2005 emissions of 630,310 MT of C02e by 15 percent in accordance with CARB Scoping Plan Guidance. Reducing 2005 GHG emission levels by 15 percent is consistent with CAR B's 2020 emission target of reducing emissions to 1990 levels. As shown in Table 1, target emissions for 2020 (i.e., 1990 levels) were estimated at 535,773 MT of C02e. Table 1 City of Carlsbad's Projected Emissions Forecast CAP GHG Community Modified Reduction Emissions with CAP GHG Em1ss1on Year Baseline Forecast Measures GHG Reductions Emissions Target1 Target Met? 2020 473,082 53,120 419,962 535,763 Yes 2025 467,018 97,386 369,632 464,328 N/A 2030 452,762 141,654 311,108 392,893 Yes 2035 455,556 185,919 269,637 321,458 Yes Note: All values in MT . 1 Based on EO 5-3-05 targets . Source: City of Carlsbad 2015b As shown in Table 1, under the assumptions of the "modified baseline," the City is projected to meet the requirements of AB 32 (i.e., reducing GHG emissions to 1990 levels by 2020). The City of Carlsbad has also developed emissions reduction measures that extend to 2035. As shown in Table 1, the forecasted emissions for the City of Carlsbad in 2030 are 311,108 MT, which is a 42 percent reduction from the 1990 emissions level of 535,763 MT. Therefore, the City's CAP is in line to meet the requirements of SB 32, which mandates a 40 percent reduction below 1990 levels by 2030. As a result, the Carlsbad CAP is consistent with SB 32 . The California Air Pollution Control Officers Association (CAPCOA) published screening thresholds to help determine which projects are considered significant and require GHG analysis and mitigation. Based on these, the City of Carlsbad CAP determined that new development projects emitting less than 900 MT of C02e annually would not have a significant impact and therefore do not need to demonstrate consistency with the CAP. Projects equal to or exceeding the 900 MT threshold would be subject to the City's CAP GHG reduction measures. In addition, the City of Carlsbad's CAP Project Review Checklist lists several non-exclusive reduction measures that projects must implement or demonstrate are non-applicable to the project to remain consistent with the CAP. These measures are codified by several City ordinances, which are noted below, and include installing photovoltaic panels for renewable energy generation; LED lighting; electric vehicle chargers; solar water or electric resistance heaters or heat pumps; and complying with energy efficiency standards. Additionally, projects may be required to develop a Transportation Demand Management plan to encourage alternative modes of travel such as public transportation and active transportation modes. Climate Action Plans, when developed in conjunction with General Plans, offer a legally enforceable GHG mitigation document if they meet several requirements specified by the State. CEQA Guidelines Section 15183.5 defines the following requirements for a qualified GHG emission reduction plan: 1. Quantify existing and projected GHG emissions within the plan area; Greenhouse Gas Study 13 ... ... -.. .. .. ---... .. .. -... - -.. .. ---.. -.. .. • .. ... -- Spare+ LLC BMW of Carlsbad 2. Establish a reduction target based on substantial evidence, where GHG emission are not cumulatively considerable; 3. Identify and analyze sector specific GHG emissions from Plan activities; 4. Specify policies and actions (measures) that local jurisdictions will enact and implement over time to achieve the specified reduction target; 5. Establish a tool to monitor progress and amend if necessary; and 6. Adopt in a public process following environmental review. CAPs are an efficient means for local governments to streamline future development projects. If projects conform to the General Plan specifications and are determined to not produce a significant emissions impact, they can tier off of the General Plan's Environmental Impact Report (EIR) and programmatic CAP without a project-specific EIR and public review process. The City of Carlsbad's CAP is considered a qualified GHG emission reduction plan through 2030 for the purposes of CEQA because it meets the aforementioned requirements and establishes 2020 and 2030 targets that are consistent with AB 32 and SB 32, as discussed above . City of Carlsbad Ordinances The City of Carlsbad adopted several new ordinances in March 2019 as part of the City's Climate Action Plan. These ordinances replaced several items in the City's previous CAP Conformance Checklist and apply to all new and some existing developments. Developments must demonstrate conformance with or non-applicability of each ordinance to remain compliant with the CAP. CS-347: Effective upon approval by the California Energy Commission (CEC), this ordinance requires that residential and non-residential developments incorporate energy efficiency and renewable energy provisions from the California Green Building Standards in the project design. These may include a minimum level of on-site renewable generation; enrollment in an energy portfolio that sources from at least 50 percent renewable energy; installation of a minimum amount of PV panels; utilization of water heating sourced from on-site energy or recovered energy; utilization of a heat pump, electric resistance or solar water heater; and installation of sealing, insulation and cool roofing. CS-349: Effective April 2019, this ordinance requires that new and existing residential projects and new non-residential projects incorporate EV chargers and pre-wired EV-ready charging spaces in compliance with the California Green Building Standards. The Standards include required parking space dimensions and wiring capacity as well as a determined ratio of EV-capable and EV-ready spaces to total on-site parking spaces. CS-350: Effective April 2019, this ordinance establishes guidelines for Transportation Demand Management (TDM) in the City of Carlsbad to foster compliance with the Climate Action Plan. Ordinance CS-350 is meant to reduce single-occupancy vehicle trips and increase alternative mode share among Carlsbad employees to help reach 2035 emissions reduction targets; support multi- modal street and neighborhood development; mitigate the effects of increased traffic on infrastructure; maintain adequate public facilities consistent with demands of projected growth; and provide more travel options that improve health, quality of life and safety of residents and employees. The ordinance incorporates by reference a TDM Handbook prepared by the City Engineer to achieve these goals . 14 ... .. -.. -.. ... .. - • -.. - • - .. • .. • • .. - .. ... -- Impact Analysis 3 Impact Analysis 3.1 Methodology Calculations of CO2, CH4, and N2O emissions are provided to identify the magnitude and nature of the proposed project's potential GHG emissions and environmental effects. The analysis focuses on CO2, CH4, and N2O because these make up 98.9 percent of all GHG emissions by volume and are the GHG emissions that the project would emit in the largest quantities (IPCC 2007). Fluorinated gases, such as HFCs, PFCs, and SF6, were also considered for the analysis. However, since fluorinated gases are primarily associated with industrial processes, and the proposed project involves a commercial use, the quantity of fluorinated gases would not be significant. Small amounts of other GHGs (such as chlorofluorocarbons [CFCs]) would also be emitted; however, these other GHG emissions would not substantially add to the total GHG emissions. Emissions of all GHGs are converted into their equivalent GWP in MT of CO2e. Calculations are based on the methodologies discussed in the California Air Pollution Control Officers Association (CAPCOA) CEQA and Climate Change white paper (CAPCOA 2008). GHG emissions associated with the proposed project were calculated using the California Emissions Estimator Model (CalEEMod) version 2016.3.2 (see Appendix A for CalEEMod worksheets) . Construction Emissions Construction activities emit GHGs primarily though combustion of fuels (mostly diesel) in the engines of off-road construction equipment and through combustion of diesel and gasoline in on- road construction vehicles and in the commute vehicles of construction workers. Smaller amounts of GHGs are also emitted indirectly through the energy use embodied in any water use for fugitive dust control and lighting for construction activity. Every phase of the construction process, including demolition, grading, paving, and building, emits GHG emissions in volumes proportional to the quantity and type of construction equipment used. Heavier equipment typically emits more GHGs per hour of use than lighter equipment due to greater fuel consumption and engine design. Although construction activity is addressed in this analysis, CAPCOA does not discuss whether any of the suggested threshold approaches adequately address impacts from temporary construction activity. As stated in the CEQA and Climate Change technical advisory, "more study is needed to make this assessment or to develop separate thresholds for construction activity" (CAPCOA 2008) . The AEP Climate Change Committee white paper Beyond Newhall and 2020 recommends evaluating construction emissions using one of two methods (2016): 1. Using Best Management Practices (BMPs). Construction-related emissions would be less than significant if a project implements all feasible BMPs, including using alternatively-fueled vehicles, reducing worker trips, and sourcing construction materials from local sources when possible (without substantial cost implications). 2. Amortizing Construction Emissions over the Operational Lifetime. Construction-related emissions are quantified and amortized over the lifetime of a project. The amortized construction emissions are added to the operational emissions to calculate the total annual emissions. If the annual emissions are below quantitative thresholds, construction-related GHG emissions would be less than significant . Greenhouse Gas Study 15 ... .. .. .. .. -.. .. .. .. .. .. .. -.. -.. -... ... • .. - ... -.. • • .. .. -... - Spare+ LLC BMW of Carlsbad This analysis utilizes the second option for evaluating construction emissions. The San Diego County Air Pollution Control District (SDAPCD) does not provide a recommended period of amortization for construction emissions. Therefore, because the jurisdiction of the South Coast Air Quality Management District (SCAQMD) is adjacent to that of SDAPCD, this analysis relies on the recommendation of SCAQMD to amortize construction emissions over a period of 30 years (the assumed life of the project; SCAQMD 2008). In the absence of project-specific information, the construction schedule and construction equipment list were based on CalEEMod defaults, which estimate that project construction would be completed over the course of approximately 15 months. For this analysis, it was assumed that construction would commence in January 2020 and would be completed by March 2021. It is assumed that all construction equipment used would be diesel-powered. Complete results from CalEEMod and assumptions can be viewed Appendix A . Operational Emissions CalEEMod calculates operational emissions of CO2, CH4, and N2O associated with energy use, area sources, waste generation, water use and conveyance. CalEEMod also calculates emissions of CO 2 and CH4 generated by project-generated vehicle trips (i.e., mobile sources). However, CalEEMod does not calculate N2O emissions from mobile sources; therefore, N2O emissions were quantified separately using guidance from CARB (see Mobile Source Emissions for a detailed discussion of methodology). Area Source Emissions Area sources include GHG emissions that would occur from the use of landscaping equipment. The use of landscape equipment emits GHGs associated with the equipment's fuel combustion. The landscaping equipment emission values were derived from the 2011 Off-Road Equipment Inventory Model. Energy Use Emissions As a result of the consumption of electricity and natural gas during project operation, GHGs are emitted on-site during the combustion of natural gas for space and water heating and cooking and off-site during the generation of electricity from fossil fuels in power plants. CalEEMod estimates GHG emissions from energy use by multiplying average rates of non-residential energy consumption by the quantity of non-residential square footage entered in the land use module to obtain total projected energy use. This value is then multiplied by electricity and natural gas GHG emission factors applicable to the project location and utility provider . Building energy use is typically divided into energy consumed by the built environment and energy consumed by uses that are independent of the building, such as plug-in appliances. Non-building energy use, or "plug-in energy use," can be further subdivided by specific end-use (refrigeration, cooking, office equipment, etc.). In California, Title 24 governs energy consumed by the built environment, mechanical systems, and some types of fixed lighting. Because project construction is assumed to begin in January 2020, the project would be constructed in accordance with the 2019 Building Energy Efficiency Standards. Nonresidential buildings built in accordance with the 2019 Building Energy Efficiency Standards will use approximately 30 percent less energy than those constructed under the 2016 standards due to lighting upgrades (CEC 2018). Therefore, the electricity-related energy reductions achieved via compliance with the 2019 Building Energy Efficiency Standards were included in CalEEMod for the proposed commercial land use. In addition, 16 .. .. .. .. .. • -.. -.. - -.. - - • - - Impact Analysis the 103 kW solar array required per City Ordinance CS-347 would generate approximately 152,646 kWh of electricity per year and was included in the Cal EE Mod model. The project would be served by SDG&E. Therefore, San Diego Gas and Electric (SDG&E)'s specific energy intensity factors (i.e., the amount of CO2, CH4, and N2O per kilowatt-hour) are used in the calculations of GHG emissions. SDG&E had renewable energy procurement of 44 percent in 2017 (EPIC 2016; CEC 2018). Per SB 100, the statewide RPS Program requires electricity providers to increase procurement from eligible renewable energy sources to 33 percent by 2020 and 44 percent by 2024. However, the default energy intensity factors included in CalEEMod are based on data from 2009. Since SDG&E met its required renewable procurement for 2024 under SB 100 in 2017, it is conservatively assumed that SDG&E will not increase its renewable energy procurement percentage from now until 2024. Therefore, the 2017 SDG&E intensity factor of 465 pounds per megawatt hour (MWh) for CO2e was included in CalEEMod for the proposed project scenario (CEC 2018b; SDG&E 2017a and 2017b). Solid Waste Emissions The disposal of solid waste produces GHG emissions from the transportation of waste, anaerobic decomposition in landfills, and incineration. To calculate the GHG emissions generated by solid waste disposal, the total volume of solid waste was calculated using waste disposal rates identified by the California Department of Resources Recycling and Recovery (Cal Recycle). The methods for quantifying GHG emissions from solid waste are based on the IPCC method using the degradable organic content of waste. GHG emissions associated with the project's waste disposal were calculated using these parameters. According to a Cal Recycle report to the Legislature, as of 2013 California had achieved a statewide 50 percent diversion of solid waste from landfills through "reduce/recycle/compost" programs. However, AB 341 mandates that 75 percent of the solid waste generated be reduced, recycled, or composted by 2020. Therefore, to account for the continuing actions of recycling requirements under state law (i.e., AB 341), an additional 25 percent solid waste diversion rate was included in CalEEMod as "mitigation" for solid waste emissions, which is a term of art for the modeling input and is not equivalent to mitigation measures that may apply to the CEQA impact analysis. Water and Wastewater Emissions The amount of water used and the amount of wastewater generated by a project generate indirect GHG emissions. These emissions are a result of the energy used to supply, convey, and treat water and wastewater. In addition to the indirect GHG emissions associated with energy use, the wastewater treatment process itself can directly emit both CH4 and N2O. The indoor and outdoor water use consumption data for each land use subtype comes from the Pacific lnstitute's Waste Not, Want Not: The Potential for Urban Water Conservation in California (2003) (CAPCOA 2017). Based on that report, a percentage of total water consumption was dedicated to landscape irrigation, which is used to determine outdoor water use. Wastewater generation was similarly based on a reported percentage of total indoor water use. New development would be subject to CalGreen, which requires a 20 percent increase in indoor water use efficiency. Thus, in order to account for compliance with Cal Green, a 20 percent reduction in indoor water use was included in the water consumption calculations for the proposed project. In addition to water reductions associated with building code compliance and project design features, the GHG emissions from the energy used to transport the water for the proposed project scenario account for compliance with the RPS as discussed under Energy Use Emissions. Greenhouse Gas Study 17 .. .. -.. - • -- .. -- -- • .. - - - - 111 .. - .. .. Spare+ LLC BMW of Carlsbad Mobile Source Emissions GHG emissions from vehicles are generated by the combustion of fossil fuels in vehicle engines. Vehicle emissions are calculated based on the vehicle type and the trip rate for each land use. Trip generation rates were based on CalEEMod defaults for each land use. However, a pending trip generation and traffic analysis to be performed in compliance with City Ordinance CS-350 should be incorporated in a future update to this analysis. The vehicle emission factors and fleet mix used in CalEEMod are derived from CARB's Emission Factors 2011 model, which includes GHG reductions achieved by implementation of Pavley I (Clean Car Standards) and the Low Carbon Fuel Standard and are thus considered in the calculation of standards for project emissions. To comply with the City's electric vehicle ordinance CS-349, fifteen EV charging spaces would be required among the 487 total parking spaces (3.1 percent) because the project would increase on- site parking by 293 spaces above existing conditions. The project would also be required to have fourteen additional EV-ready spaces (i.e., pre-wired for charging). To account for EV charging infrastructure, VMT and associated emissions from fossil fuel powered vehicles was reduced to reflect the emissions associated with the fifteen EV charging spaces. To estimate the change in emissions from EVs, total VMT and associated emissions were reduced by 3.1 percent. This VMT was then converted to electricity consumption using a kWh to VMT conversion factor and the emission factor for SDG&E (United States Department of Energy 2018). The resulting emissions were then combined with the remaining mobile emissions. A detail of this EV calculation is included in Appendix C. Because CalEEMod does not calculate N20 emissions from mobile sources, N20 emissions were quantified using guidance from CARB (CARB 2013; see Appendix C for calculations), which states the following: ■ For gasoline vehicles, use 4.16 percent of NO. emissions (from CalEEMod) to calculate N20 for all gasoline vehicles; and ■ For diesel vehicles, use 0.3316 grams of NOx per gallon fuel used. Cal EE Mod does not list the percentage breakdown of gasoline and diesel vehicles used in the model's fleet mixes. To determine this percentage, the EMFAC 2014 Emissions Inventory was obtained in a spreadsheet output for the San Diego County region for the project's operational year (2021), using EMFAC 2011 categories (CARB 2019). 3.2 Significance Thresholds State CEQA Guidelines Based on Appendix G of the 2019 State CEQA Guidelines, impacts related to GHG emissions from the project would be significant if the project would: 1. Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; and/or 2. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs . 18 .. .. - -.. .. • - • • - --.. ... -- • -.. - -... Impact Analysis In addition, CEQA Guidelines Section 15064.4(b) states that a lead agency should consider the following factors, among others, when assessing the significance of impacts from GHG emissions on the environment: 1. The extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting; 2. Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project; and 3. The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. Such requirements must be adopted by the relevant public agency through a public review process and must reduce or mitigate the project's incremental contribution of GHG emissions . The vast majority of individual projects do not generate sufficient GHG emissions to create significant project-specific environment effects. However, the environmental effects of a project's GHG emissions can contribute incrementally to cumulative environmental effects that are significant, contributing to climate change, even if an individual project's environmental effects are limited (CEQA Guidelines Section 15064[h][l]). The issue of a project's environmental effects and contribution towards climate change typically involves an analysis of whether or not a project's contribution towards climate change is cumulatively considerable. Cumulatively considerable means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects (CEQA Guidelines Section 15064[h][l]). CEQA Guidelines Section 15064.4 does not establish a threshold of significance. Lead agencies have the discretion to establish significance thresholds for their respective jurisdictions, and in establishing those thresholds, a lead agency may appropriately look to thresholds developed by other public agencies, or suggested by other experts, as long as any threshold chosen is supported by substantial evidence (CEQA Guidelines Section 15064. 7(c]) . The Association of Environmental Professionals' (AEP) Beyond Newhall and 2020 white paper identifies the following four methods described are the most widely used evaluation criteria (AEP 2016): • Consistency with a Qualified GHG Reduction Plan. For a project located within a jurisdiction that has adopted a qualified GHG reduction plan (as defined by CEQA Guidelines Section 15183.5), GHG emissions would be less than significant if the project is anticipated by the plan and fully consistent with the plan. However, projects with a horizon year beyond 2020 should not tier from a plan that is qualified up to only 2020 . • Bright Line Thresholds. There are two types of bright line thresholds: □ Standalone Threshold. Emissions exceeding standalone thresholds would be considered significant. □ Screening Threshold. Emissions exceeding screening thresholds would require evaluation using a second tier threshold, such as an efficiency threshold or other threshold concept to determine whether project emissions would be considered significant. However, projects with a horizon year beyond 2020 should take into account the type and amount of land use projects and their expected emissions out to the year 2030. Greenhouse Gas Study 19 -... -... ... -.. .. .. -- --.. .. - .. • .. .. • Spare+ LLC BMW of Carlsbad • Efficiency Thresholds. Land use sector efficiency thresholds are currently based on AB 32 targets and should not be used for projects with a horizon year beyond 2020. Efficiency metrics should be adjusted for 2030 and include applicable land uses . • Percent Below "Business as Usual" (BAU). GHG emissions would be less than significant if the project reduces BAU emissions by the same amount as the statewide 2020 reductions. However, this method is no longer recommended following the Newhall Ranch ruling (AEP 2016) . Neither the State of California nor the San Diego Air Pollution Control District (SDACPD; the air district regulatory entity) has adopted emission-based thresholds for GHG emissions under CEQA . However, as discussed under Section 2.4, Regulatory Setting, the City of Carlsbad adopted a CAP in September 2015 that is a current and qualified GHG reduction plan through 2030 for the purposes of CEQA. According to CEQA Guidelines Section 15183.5, project-specific environmental documents can tier from, or incorporate by reference, the existing programmatic review in a qualified GHG reduction plan, which allows for project-level evaluation of GHG emissions through the comparison of the project's consistency with the qualified GHG reduction plan. This approach is considered by AEP to be the most defensible approach presently available under CEQA to determine the significance of a project's GHG emissions (AEP 2016). A key aspect of a qualified GHG reduction plan is substantial evidence that the identified reduction target establishes a threshold where GHG emissions are not cumulatively considerable. The City's CAP establishes a screening threshold of 900 MT of CO2e per year and demonstrates that GHG emission reductions would be consistent with AB 32 and SB 32 with use of this screening threshold. Therefore, if a project that can demonstrate that its annual projected GHG emissions would be below the 900 MT of CO2e threshold, the project would be consistent with the City's CAP, and emissions related to the project would be considered less than significant under CEQA. 3.3 Project Impacts Construction Emissions As shown in Table 2, project construction would generate an estimated 595 MT of CO2e. Amortized over a 30-year period, project construction would generate approximately 20 MT of CO2e per year. Table 2 Estimated Construction Emissions 20 2020 2021 Total Amortized over 30 years See Appendix A for CalEEMod results . Annual Emissions (MT C02e) 511.5 83.5 595.0 19.8 ... .. .. .. -.. .. .. • • .. .. Impact Analysis Combined Construction, Stationary, and Mobile Source Emissions Table 3 combines the amortized construction (Table 2), operational, and mobile GHG emissions associated with the project and shows the change in emissions compared to the current site use. Total project emissions exceed the CAP threshold of 900 MT of CO2e per year for new development projects. However, once existing uses are subtracted from the project emissions, overall emissions would decrease below the threshold. Since the change in GHG emissions on site would not exceed the significance screening threshold established in the CAP, the project would not generate a substantial increase in GHG emissions and would not conflict with the City of Carlsbad GHG reduction goals or with AB 32 or SB 32. Table 3 Combined Annual Project Emissions Project Emissions Current Emissions Change in Emissions Emission Source (MT of C02e/year) (MT of C02e/year) (MT of C02e/year) Construction 19.8 0 19.8 Operational Area <0.1 <0.1 <0.1 Energy 218.5 94.7 123.8 Solid Waste 77.8 57.0 20.8 30.6 15.5 15.1 Water Mobile CO2 and CH4 957.0 308.2 648.8 N20 17.3 6.8 10.5 Total 1,321.0 482.2 838.8 CAP Threshold 900 Threshold Exceeded? No See Appendices A and B for CalEEMod results . Greenhouse Gas Study 21 .. ... ... -.. .. ... ... .. .. -.. - • • • --.. • .. - .. -.,, ... .. .. Spare+ LLC BMW of Carlsbad 4 Conclusion The BMW of Carlsbad project will reduce on-site commercial use from two buildings and multiple operators to one operator-owned building. In replacing two single-story buildings with one multi- story building, building area will increase by approximately 39,868 sf. Landscaped area will decrease by approximately 19,175 sf and parking will increase by 293 spaces inclusive of ground level, enclosed, and rooftop parking areas. The size and character of the BMW of Carlsbad project does not substantially differ from the land uses encompassed in Specific Plan 19 and is intended to comply with the City General Plan's Land Use and Community Design Element and Coastal Zone requirements. The General Plan designates the location as Regional Commercial (R), including region-serving shopping centers and commercial developments such as automotive sales and service facilities. The project site use remains consistent with the General Plan and the current use of commercial automotive service. The project thus is not expected to substantially alter the emissions that were anticipated under the buildout assumptions contained in the General Plan approved in 2015. The City of Carlsbad has developed a SB 32 (2030)-compliant Climate Action Plan which serves as mitigation for the General Plan. Projects in the City are required to follow the City of Carlsbad CAP and CAP Project Review Checklist, requiring them to incorporate a combination of reduction measures to mitigate an increase in GHG emissions. A project would need to implement and document on the Checklist strategic emission reduction measures such as photovoltaic panels for renewable energy generation, electric vehicle chargers, solar water heaters or heat pumps, LED lighting and greywater, or other state recommended actions to demonstrate how it plans to remain consistent with the CAP's targets. By following this guideline, the proposed project would be able to show conformance with the City of Carlsbad CAP and statewide GHG regulations . The City of Carlsbad has an adopted a land use and emission-based screening threshold for new development projects in the City. Since the proposed project would increase the developed area on site, it must complete the CAP Checklist and conform to the City's new ordinances requiring EV chargers, solar photovoltaics, and TOM programs. As shown above, the project would increase overall GHG emissions, but the net increase from current site usage would not exceed the 900 MT screening threshold. By completing the CAP Checklist and conforming to the required ordinances, the proposed project would be consistent with the City of Carlsbad CAP. Furthermore, the project would be consistent with applicable land use and zoning designations, would not conflict with any state regulations intended to reduce GHG emissions statewide, and would be consistent with applicable plans and programs designed to reduce GHG emissions. Therefore, no mitigation measures beyond those encompassed in the CAP Checklist are recommended . 22 .. .. .. ... .. .. ... .. .. .. .. - - • • .. .. .. ---- • -----.. - References 5 References Association of Environmental Professionals (AEP). 2016. Final White Paper Beyond 2020 and Newhall: A Field Guide to New CEQA Greenhouse Gas Thresholds and Climate Action Plan Targets for California. https://www.califaep.org/images/climate-change/ AEP- 2016_Final_ White_Paper.pdf (accessed July 2019). California Air Pollution Control Officers Association (CAPCOA). 2008 CEQA and Climate Change . http://www.capcoa.org/wp-content/uploads/downloads/2010/05/CAPCOA-White-Paper.pdf (accessed July 2019). __ . 2017. California Emissions Estimator Model User Guide: Version 2016.3.2. Prepared by BREEZE Software, A Division of Trinity Consultants in collaboration with South Coast Air Quality Management District and the California Air Districts. http://www.aqmd.gov/docs/default- source/ca1eemod/user's-guide---october-2017.pdf?sfvrsn=6 (accessed July 2019) . California Air Resources Board (CARB). 2011. 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