HomeMy WebLinkAbout04_07_GHGCity of South San Francisco
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4.7 Greenhouse Gas Emissions
4.7.1 Introduction
This section describes the environmental and regulatory setting for greenhouse gas (GHG) emissions.
It also describes impacts associated with GHG emissions that would result from implementation of the
proposed project and mitigation for significant impacts where feasible and appropriate.
4.7.2 Environmental Setting
4.7.2.1 Global Climate Change
The process known as the greenhouse effect keeps the atmosphere near Earth’s surface warm
enough for the successful habitation of humans and other life forms. The greenhouse effect is
created by sunlight that passes through the atmosphere. Some of the sunlight striking Earth is
absorbed and converted to heat, which warms the surface. The surface emits a portion of this heat as
infrared radiation, some of which is re-emitted toward the surface by GHGs. Human activities that
generate GHGs increase the amount of infrared radiation absorbed by the atmosphere, thereby
enhancing the greenhouse effect and amplifying the warming of Earth.
Increases in fossil fuel combustion and deforestation have exponentially increased concentrations of
GHGs in the atmosphere since the Industrial Revolution.1 Rising atmospheric concentrations of
GHGs in excess of natural levels result in increasing global surface temperatures—a process
commonly referred to as global warming. Higher global surface temperatures, in turn, result in
changes to Earth’s climate system, including increases in ocean temperatures and acidity, less sea
ice, variable precipitation, and increased frequencies and intensities for extreme weather events.2
Large-scale changes to Earth’s system are collectively referred to as climate change.
The Intergovernmental Panel on Climate Change (IPCC) was established by the World
Meteorological Organization and United Nations Environment Programme to assess scientific,
technical, and socioeconomic information relevant to the understanding of climate change, its
potential impacts, and options for adaptation and mitigation. The IPCC estimates that human-
induced warming reached approximately 1 degree Celsius (°C) above pre-industrial levels in 2017,
increasing at 0.2°C per decade. Under the current nationally determined contributions of mitigation,
global warming is expected to increase 3°C by 2100 and continue afterwards.3 Large increases in
global temperatures could have substantial adverse effects on natural and human environments in
California and worldwide.
1 Intergovernmental Panel on Climate Change. 2007. Climate Change 2007: The Physical Science Basis.
Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate
Change. Available: https://www.ipcc.ch/site/assets/uploads/2018/05/ar4_wg1_full_report-1.pdf. Accessed:
January 7, 2020.
2 Intergovernmental Panel on Climate Change. 2018. Global Warming of 1.5°C. Contribution of Working Group I, II,
and III (Summary for Policy Makers). Available: https://www.ipcc.ch/site/assets/uploads/sites/2/2019/05/
SR15_ SPM_ version_report_LR.pdf. Accessed: January 7, 2020.
3 Ibid.
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4.7.2.2 Greenhouse Gases
The principal anthropogenic (human-made) GHGs contributing to global warming are carbon
dioxide (CO2), methane (CH4), nitrous oxide (N2O), and fluorinated compounds, including sulfur
hexafluoride (SF6), hydrofluorocarbons (HFCs), and perfluorocarbons. Water vapor, the most
abundant GHG, is not included in this list because its natural concentrations and fluctuations far
outweigh its anthropogenic sources.
The primary GHGs of concern associated with the project are CO2, CH4, and N2O. The principal
characteristics of these pollutants are discussed below.
CO2 enters the atmosphere through fossil-fuel (oil, natural gas, coal) combustion, solid waste
decomposition, plant and animal respiration, and chemical reactions (e.g., from the manufacture of
cement). CO2 is also removed from the atmosphere (or sequestered) when it is absorbed by plants as
part of the biological carbon cycle.
CH4 is emitted during the production and transport of coal, natural gas, and oil. CH4 emissions also
result from livestock and agricultural practices as well as the decay of organic waste in municipal
solid waste landfills.
N2O is emitted during agricultural and industrial activities as well as the combustion of fossil fuels
and solid waste.
Methods have been set forth to describe emissions of GHGs in terms of a single gas to simplify
reporting and analysis. The most commonly accepted method for comparing GHG emissions is the
global warming potential (GWP) methodology defined in IPCC reference documents. IPCC defines
the GWP of various GHG emissions on a normalized scale that recasts all GHG emissions in terms of
the carbon dioxide equivalent (CO2e), which compares the gas in question to that of the same mass
of CO2 (CO2 has a global warming potential of 1 by definition).
Table 4.7-1 lists the global warming potential of CO2, CH4, and N2O and their lifetimes in the
atmosphere.
Table 4.7-1. Lifetimes and Global Warming Potentials of Key Greenhouse Gases
Greenhouse Gas
Global Warming Potential
(100 years)
Lifetime
(years)
Carbon dioxide (CO2) 1 —a
Methane (CH4) 25 12
Nitrous oxide (N2O) 298 114
Source: California Air Resources Board. 2020a. GHG Global Warming Potentials. Available: https://ww2.arb.ca.gov/
ghg-gwps. Accessed: January 7, 2020.
a No lifetime (years) for CO2 was presented by the California Air Resources Board.
The California Air Resources Board (CARB) recognizes the importance of reducing emissions of
short-lived climate pollutants (described in Section 4.7.3, Regulatory Framework) to the atmosphere
to achieve the State’s overall climate change goals. Short-lived climate pollutants have atmospheric
lifetimes on the order of a few days to a few decades. Their relative climate-forcing impacts, when
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measured in terms of how they heat the atmosphere, can be tens, hundreds, or even thousands of
times greater than that of CO2.4 Recognizing their short-term lifespan and warming impact, short-
lived climate pollutants are measured in terms of CO2e, using a 20-year time period. The use of
GWPs with a time horizon of 20 years captures the importance of the short-lived climate pollutants
and gives a better perspective regarding the speed at which emissions controls affect the
atmosphere relative to CO2 emissions controls. The Short-Lived Climate Pollutant Reduction
Strategy, discussed in Section 4.7.3, Regulatory Framework, addresses CH4, HFC gases, and
anthropogenic black carbon. CH4 has lifetime of 12 years and a 20-year GWP of 72. HFC gases have
lifetimes of 1.4 to 52 years and a 20-year GWP of 437 to 6,350. Anthropogenic black carbon has a
lifetime of a few days to weeks and a 20-year GWP of 3,200.5
4.7.2.3 Greenhouse Gas Reporting
A GHG inventory is a quantification of all GHG emissions and sinks6 within a selected physical
and/or economic boundary. GHG inventories can be performed on a large scale (e.g., for global and
national entities) or on a small scale (e.g., for a building or person). Although many processes are
difficult to evaluate, several agencies have developed tools to quantify emissions from certain
sources. Table 4.7-2 outlines the most recent global, national, statewide, and local GHG inventories
to help contextualize the magnitude of potential project-related emissions.
Table 4.7-2. Global, National, State, and Regional Greenhouse Gas Emission Inventories
Emissions Inventory
Carbon Dioxide Equivalent
(CO2e) (metric tons)
2010 IPCC Global GHG Emission Inventory 52,000,000,000
2018 Environmental Protection Agency National GHG
Emissions Inventory
6,676,600,000
2017 CARB State GHG Emissions Inventory 424,100,000
2015 Bay Area Air Quality Management District GHG Emissions
Inventory
85,000,000
2005 South San Francisco Inventory 548,600
Sources:
Bay Area Air Quality Management District. 2017a. Final 2017 Clean Air Plan. Adopted April 19. Available:
https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-air-plan/attachment-a_-
proposed-final-cap-vol-1-pdf.pdf?la=en. Accessed: January 6, 2020.
California Air Resources Board. 2020b. GHG Current California Emission Inventory Data (2017). Available:
https://ww2.arb.ca.gov/ghg-inventory-data. Accessed: January 7, 2020.
Intergovernmental Panel on Climate Change. 2014. Climate Change Synthesis Report. Available:
https://www.ipcc.ch/site/assets/uploads/2018/02/SYR_AR5_FINAL_full.pdf. Accessed: January 7, 2020.
City of South San Francisco. 2014. City of South San Francisco Climate Action Plan. Adopted February 13. Available:
https://www.ssf.net/home/showdocument?id=1318. Accessed: January 7, 2020.
U.S. Environmental Protection Agency. 2020. Inventory of U.S. Greenhouse Gas Emissions and Sinks (2018). Last
updated: April 13. Available: https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-
sinks. Accessed: April 20, 2020.
4 California Air Resources Board. 2017. Short-Lived Climate Pollutant Reduction Strategy. Available:
https://ww2.arb.ca.gov/sites/default/files/2018-12/final_slcp_report%20Final%202017.pdf. Accessed:
January 7, 2020.
5 Ibid.
6 A GHG sink is a process, activity, or mechanism that removes a GHG from the atmosphere.
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4.7.2.4 Potential Climate Change Effects
Climate change is a complex process that has the potential to alter local climatic patterns and
meteorology. Although modeling indicates that climate change will result in sea-level rise (both
globally and regionally) as well as changes in climate and rainfall, among other effects, there
remains uncertainty about characterizing precise local climate characteristics and predicting
precisely how various ecological and social systems will react to changes in the existing climate at
the local level. Regardless of this uncertainty, it is widely understood that substantial climate
change is expected to occur in the future, although the precise extent will take further research to
define. Specifically, significant impacts from global climate change in California and worldwide
could include:
l Declining sea ice and mountain snowpack levels, thereby increasing sea levels and sea surface
evaporation rates, with a corresponding increase in atmospheric water vapor due to the
atmosphere’s ability to hold more water vapor at higher temperatures.7
l Rising average global sea levels, primarily due to thermal expansion and the melting of glaciers,
ice caps, and the Greenland and Antarctic ice sheets.8
l Changing weather patterns, including changes in precipitation and wind patterns, and more
energetic episodes of extreme weather, including droughts, heavy precipitation, heat waves,
extreme cold, and intense tropical cyclones.9
l Declining Sierra Mountain snowpack levels, which account for approximately half of the surface
water storage in California. Snow levels could decline by 70 to as much as 90 percent over the
next 100 years.10
l Increases in the number of days that could be conducive to ozone formation (e.g., clear days
with intense sunlight) by the end of the 21st century in high ozone areas.11 The number of days
could increase by 25 to 85 percent, depending on the future temperature scenario.
l Increases in the potential for erosion of California’s coastlines as well as seawater intrusion into
the Sacramento Delta and associated levee systems due to the rise in sea level.12
l The severity of drought conditions in California could be exacerbated (e.g., durations and
intensities could be amplified, ultimately increasing the risk of wildfires and consequential
damage).13
7 California Natural Resources Agency. 2018. California’s Fourth Climate Change Assessment Statewide Summary
Report. Available: http://www.climateassessment.ca.gov/state/docs/20190116-StatewideSummary.pdf.
Accessed: January 7, 2020.
8 Intergovernmental Panel on Climate Change. 2018. Global Warming of 1.5°C. Contribution of Working Group I, II,
and III (Summary for Policy Makers). Available:
https://www.ipcc.ch/site/assets/uploads/sites/2/2019/05/SR15_SPM_version_report_LR.pdf. Accessed:
January 7, 2020.
9 Ibid.
10 California Natural Resources Agency. 2018. California’s Fourth Climate Change Assessment Statewide Summary
Report. Available: http://www.climateassessment.ca.gov/state/docs/20190116-StatewideSummary.pdf.
Accessed: January 7, 2020.
11 Ibid.
12 Ibid.
13 Ibid.
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l Under changing climate conditions, agricultural operations are forecast to experience lower
crop yields due to extreme heat waves, heat stress, increased water needs of crops and livestock
(particularly during dry and warm years), and new and changing pest and disease threats.14
l The impacts of climate change, such as increased numbers of heat-related events, droughts, and
wildfires, pose direct and indirect risks to public health, with people experiencing worsening
episodes of illness and an earlier death. Indirect impacts on public health include increases in
incidents of vector-borne diseases, stress and mental trauma due to extreme events and
disasters, economic disruptions, and residential displacement.15
4.7.3 Regulatory Framework
4.7.3.1 International
In 2015, the twenty-first session of the Conference of Parties (COP21) took place in Paris, France. The
session included representatives from 196 parties to the United Nations Framework Convention on
Climate Change. The Paris Agreement included limiting global temperature increases to well below
2°C, establishing binding commitments so all parties make Nationally Determined Contributions
(NDCs) as well as pursuing domestic policies to achieve the NDCs, and having all countries report
regularly regarding their emissions and progress made in implementing and achieving their NDCs. In
April 2016, 174 states and the European Union signed the agreement, including the United States.
However, on November 4, 2019, President Donald Trump formally notified the United Nations that the
United States would withdraw from the Paris Agreement. The United States has begun the 1-year
process of exiting the deal, which can occur no sooner than November 2020.
The Under2 Coalition is an international coalition of jurisdictions that signed the Global Climate
Leadership Memorandum of Understanding (Under2 MOU) following President Trump’s decision to
withdraw from the Paris Agreement. Under2 MOU aims to limit global warming to 2°C, limit GHGs to
below 80 to 95 percent below 1990 levels, and/or achieve a per capita annual emissions goal of less
than 2 metric tons by 2050. Under2 MOU has been signed or endorsed by 135 jurisdictions, including
California, representing 32 countries and six continents.
4.7.3.2 Federal
There is currently no federal overarching law related specifically to climate change or reductions in
GHG emissions. Under the Obama administration, the U.S. Environmental Protection Agency (EPA) had
been developing regulations under the Clean Air Act (CAA). There have also been settlement
agreements between EPA, several states, and nongovernmental organizations to address GHG
emissions from electric generating units and refineries. In addition, EPA issued an Endangerment
Finding and a Cause or Contribute Finding. EPA has also adopted a Mandatory Reporting Rule and
Clean Power Plan. Under the Clean Power Plan, EPA issued regulations to control CO2 emissions from
new and existing coal-fired power plants. However, on February 9, 2016, the Supreme Court issued a
stay regarding these regulations pending litigation. In addition, former EPA Administrator Scott Pruitt
signed a measure to repeal the Clean Power Plan. The fate of the proposed regulations is uncertain,
given the change in federal administrations and the pending deliberations in federal courts.
14 Ibid.
15 Ibid.
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The National Highway Traffic Safety Administration (NHTSA) sets the Corporate Average Fuel
Economy (CAFÉ) standards to improve average fuel economy and reduce GHG emissions
generated by cars and light-duty trucks. NHTSA and EPA have proposed amendments to the
current fuel efficiency standards for passenger cars and light-duty trucks and new standards for
model years 2021 through 2026. Under the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule,
current 2020 standards would be maintained through 2026. California, 22 other states, the
District of Columbia, and two cities filed suit against the proposed action on September 20, 2019
(California et al. v. United States Department of Transportation et al., 1:19-cv-02826, U.S. District
Court for the District of Columbia). The lawsuit requests a “permanent injunction prohibiting
defendants from implementing or relying on the preemption regulation” but does not stay its
implementation during legal deliberations. Part 1 of the SAFE Vehicles Rule went into effect on
November 26, 2019. Part 2 of the rule was finalized on March 30, 2020. The rule will decrease
the stringency of the CAFÉ standards 1.5 percent each year through model year 2026; the
standards issued in 2012 would have required annual fuel efficiency increases of about 5
percent.
4.7.3.3 State
California has adopted statewide legislation to address various aspects of climate change and GHG
emissions. Much of this legislation establishes a broad framework for the State’s long-term GHG
reduction and climate change adaptation program. The State’s governors have also issued several
executive orders (EOs) related to the State’s evolving climate change policy. Of particular
importance are Assembly Bill (AB) 32 and Senate Bill (SB) 32, which outline the State’s GHG
reduction goals (i.e., achieving 1990 emissions levels by 2020 and a level 40 percent below 1990
emissions levels by 2030). In the absence of federal regulations, control of GHGs is generally
regulated at the State level. It is typically approached by setting emissions reduction targets for
existing sources of GHGs, setting policies to promote renewable energy and increase energy
efficiency, and developing statewide action plans. Summaries of key policies, legal cases,
regulations, and legislation at the State level that are relevant to the proposed project are
identified below.
Assembly Bill 1493
With the 2002 passage of AB 1493, also known as Pavley I, California launched an innovative and
proactive approach to dealing with GHG emissions and climate change at the State level. AB 1493
requires CARB to develop and implement regulations to reduce GHG emissions from automobiles
and light-duty trucks. These stricter emissions standards were designed to apply to automobiles
and light-duty trucks beginning in the 2009 model year. Although litigation challenged these
regulations and EPA initially denied California’s related request for a waiver, the waiver request
was granted.16 In 2012, additional strengthening of the Pavley standards (referred to previously
as Pavley II but now referred to as the Advanced Clean Cars measure) was adopted for vehicle
model years 2017 through 2025. Together, the two standards are expected to increase average
fuel economy numbers to roughly 54.5 miles per gallon in 2025.
16 As noted above, however, California’s waiver to set state-specific standards is currently uncertain because of the
SAFE Vehicles Rule.
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Executive Order S-3-05
On June 1, 2005, Governor Arnold Schwarzenegger signed EO S-3-05. The goal of this EO was to reduce
California’s GHG emissions to (1) 2000 levels by 2010 (achieved), (2) 1990 levels by 2020, and (3)
80 percent below the 1990 levels by 2050. EO S-3-05 also called for the California Environmental
Protection Agency to prepare biennial science reports on the potential impact of continued global
warming on certain sectors of the California economy. As a result of the scientific analysis presented in
these biennial reports, a comprehensive Climate Adaptation Strategy was released in December 2009,
following extensive interagency coordination and stakeholder input. The latest of these reports, the
Climate Action Team Biennial Report, was published in December 2010.
Executive Order S-01-07
With EO S-01-07 in 2007, Governor Schwarzenegger set forth the low-carbon fuel standard (LCFS)
for California. Under this EO, the carbon intensity of California’s transportation fuels is to be reduced
by at least 10 percent by 2020.
Executive Order B-55-18
EO B-55-18 acknowledges the environmental, community, and public health risks posed by future
climate change. It further recognizes the climate stabilization goal adopted by 194 states and the
European Union under the Paris Agreement. Although the United States was not party to the
agreement, California is committed to meeting the Paris Agreement goals and going beyond them
wherever possible. Based on the worldwide scientific agreement that carbon neutrality must be
achieved by mid-century, EO B-55-18 establishes a new state goal to achieve carbon neutrality as
soon as possible, no later than 2045, and achieve and maintain net negative emissions thereafter.
The EO charges the CARB with developing a framework for implementing and tracking progress
toward these goals. This EO extends EO S-3-05 but is binding only on state agencies.
Assembly Bill 32
One goal of EO S-03-05 was further reinforced by AB 32 (Chapter 488, Statutes of 2006), the Global
Warming Solutions Act of 2006, which required the State to reduce GHG emissions to 1990 levels by
2020. Since AB 32 was adopted, CARB, the California Energy Commission (CEC), the California Public
Utilities commission (CPUC), and the Building Standards Commission have been developing
regulations to help meet the goals of AB 32. Under AB 32, CARB is required to prepare a scoping
plan and update it every 5 years. The scoping plan was approved in 2008, the First Update was
approved in 2014, and an additional update was approved in 2017 (see discussion of SB 32, below).
The scoping plan identifies specific measures for reducing GHG emissions to 1990 levels by 2020. It
also requires CARB and other state agencies to develop and enforce regulations and other initiatives
for reducing GHGs. Specifically, the AB 32 scoping plan articulates a key role for local governments,
recommending they establish GHG reduction goals for both their municipal operations and the
community consistent with those of the State. In 2018, CARB announced that inventory year 2016
emissions had dropped below 1990 levels, which would mean achievement of the AB 32 goal if
emissions continue on their current trajectory.17
17 California Air Resources Board. 2018. Climate Pollutants Fall Below 1990 Levels for the First Time. Available:
https://ww2.arb.ca.gov/news/climate-pollutants-fall-below-1990-levels-first-time. Accessed: April 20, 2020.
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Assembly Bill 939 (1989) and Assembly Bill 341 (2011)
To minimize the amount of solid waste that must be disposed of in landfills, the State legislature
passed the California Integrated Waste Management Act of 1989 (AB 939), effective January 1990.
According to AB 939, all cities and counties were required to divert 25 percent of all solid waste
from landfill facilities by January 1, 1995, and 50 percent by January 1, 2000. Through other statutes
and regulations, this 50 percent diversion rate also applies to state agencies. In order of priority,
waste reduction efforts must promote source reduction, recycling and composting, and
environmentally safe transformation and land disposal.
In 2011, AB 341 modified the California Integrated Waste Management Act and directed the
California Department of Resources Recycling and Recovery (CalRecycle) to develop and adopt
regulations for mandatory commercial recycling. As of July 1, 2012, the resulting Mandatory
Commercial Recycling Regulation required certain businesses that generate 4 cubic yards or more of
commercial solid waste per week to arrange recycling services. To comply with this requirement,
businesses may either separate recyclables and self-haul them or subscribe to a recycling service
that includes mixed-waste processing. AB 341 also established a statewide recycling goal of 75
percent; the 50 percent disposal reduction mandate still applies for cities and counties under AB
939.
Senate Bill 97
SB 97 required the Governor’s Office of Planning and Research (OPR) to develop recommended
amendments to the California Environmental Quality Act (CEQA) Guidelines for addressing GHG
emissions. The amendments became effective on March 18, 2010.
Senate Bill 350—De Leon (Clean Energy and Pollution Reduction Act of 2015)
SB 350 was approved by the California legislature in September 2015 and signed by Governor
Brown in October 2015. Its key provisions are to require the following by 2030: (1) a renewables
portfolio standard of 50 percent and (2) a doubling of energy efficiency (electrical and natural gas)
by 2030, including improvements to the efficiency of existing buildings. These mandates will be
implemented by future actions of the CPUC and CEC.
Senate Bill 375
SB 375, signed into law by Governor Schwarzenegger on September 30, 2008, became effective
January 1, 2009. This law requires the State’s 18 metropolitan planning organizations to develop
sustainable communities strategies (SCS) as part of their regional transportation plans (RTPs)
through integrated land use and transportation planning and demonstrate an ability to attain the
GHG emissions reduction targets that CARB established for the region by 2020 and 2035. This would
be accomplished through either the financially constrained SCS as part of the RTP or an
unconstrained alternative planning strategy. If regions develop integrated land use, housing, and
transportation plans that meet the SB 375 targets, new projects in these regions can be relieved of
certain CEQA review requirements.18
18 This project does not quality for streamlined CEQA review because it is not a mixed-used transit priority
project.
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Senate Bills 1078, 107, and 2
SBs 1078 (2002), 107 (2006), and 2 (2011), California’s Renewables Portfolio Standard (RPS),
obligates investor-owned utilities, energy service providers, and community choice aggregators to
procure additional retail sales each year from eligible renewable sources, with the long-range target
of procuring 33 percent of retail sales from renewable resources by 2020. The CPUC and CEC are
jointly responsible for implementing the program.
Senate Bill 32 and Assembly Bill 197
SB 32 (2016) requires CARB to ensure that statewide GHG emissions are reduced to at least
40 percent below the 1990 level by 2030, consistent with the target set forth in EO B-30-15. The
companion bill to SB 32, AB 197, creates requirements to form a joint legislative committee on
climate change policies, requires CARB to prioritize direct emission reductions and consider social
costs when adopting regulations to reduce GHG emissions beyond the 2020 statewide limit, requires
CARB to prepare reports on sources of GHGs and other pollutants, establishes 6-year terms for
voting members of CARB, and adds two legislators as non-voting members of CARB. CARB adopted
the 2017 Climate Change Scoping Plan in November 2017 to meet the GHG reduction requirement
set forth in SB 32. The updated scoping plan includes various elements, including doubling energy
efficiency savings, increasing the LCFS from 10 to 18 percent, adding 4.2 million zero-emission
vehicles on the road, implementing the sustainable freight strategy, implementing a post-2020 cap-
and-trade program, creating walkable communities with expanded mass transit and other
alternatives to traveling by car, and developing an integrated natural and working lands action plan
to protect land-based carbon sinks.
Senate Bill 605 and Senate Bill 1383
SB 605 directed CARB, in coordination with other state agencies and local air districts, to develop a
comprehensive Short-Lived Climate Pollutant (SLCP) Reduction Strategy. SB 1383 directed CARB to
approve and implement the SLCP reduction strategy to achieve the following reductions:
l 40 percent reduction in CH4 from the 2013 levels by 2030
l 40 percent reduction in HFC gases from the 2013 levels by 2030
l 50 percent reduction in anthropogenic black carbon from the 2013 levels by 2030
The bill also establishes the following targets for reducing organic waste in landfills and CH4
emissions from dairy and livestock operations:
l 50 percent reduction in organic waste disposal from the 2014 level by 2020
l 75 percent reduction in organic waste disposal from the 2014 level by 2025
l 40 percent reduction in CH4 emissions from livestock and dairy manure management operations
by 2030 compared with the livestock and dairy sectors’ 2013 levels
CARB and CalRecycle are currently developing regulations to achieve the organic waste reduction
goals found under SB 1383. In January 2019 and June 2019, CalRecycle proposed new and amended
regulations in Titles 14 and 27 of the California Code of Regulations. Among other things, the
regulations set forth minimum standards for organic waste collection, hauling, and composting. The
final regulations will take effect on or after January 1, 2022.
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Short-Lived Climate Pollutant Reduction Strategy
CARB adopted the SLCP Reduction Strategy in March 2017 as a framework for achieving the CH4,
HFC, and anthropogenic black carbon reduction targets set by SB 1383. The SLCP Reduction Strategy
includes 10 measures that fit within a wide range of ongoing planning efforts throughout the State,
including CARB’s and CalRecycle’s proposed rulemaking on organic waste diversion.
Senate Bill 100
The State’s existing renewables portfolio standard requires all retail sellers to procure a certain
amount of electricity from eligible renewable energy resources so that the total number of kilowatt-
hours sold to their retail customers equals 25 percent of sales by December 31, 2016 (achieved);
33 percent by December 31, 2020; 40 percent by December 31, 2024; 45 percent by December 31,
2027; and 50 percent by December 31, 2030. SB 100 revises and extends these renewable resource
targets to 50 percent by December 31, 2026; 60 percent by December 31, 2030; and 100 percent by
December 31, 2045.
Senate Bill 743
SB 743 requires revisions to the State CEQA Guidelines to establish new impact analysis criteria for
the assessment of a project’s transportation impacts. The intent behind SB 743 and revising the
State CEQA Guidelines is to integrate and balance the needs of congestion management, infill
development, active transportation, and GHG emissions reduction. OPR recommends that vehicle
miles traveled (VMT) serve as the primary analysis metric, replacing the existing criteria of delay
and level of service. In 2018, OPR released a technical advisory, outlining potential VMT significance
thresholds for different project types. For example, it would be reasonable to conclude that office
projects with a VMT level that is 15 percent19 less than existing conditions (2015–2018 average)
would be consistent with statewide GHG reduction targets. With respect to retail land uses, any net
increase in VMT may indicate a significant transportation impact. The new VMT methodology is
required as of July 1, 2020, although it can be used earlier.
Senate Bill X7-7
SB X7-7, the Water Conservation Act of 2009, sets a goal of reducing per capita urban water use by
20 percent by December 31, 2020. The State was required to make incremental progress toward this
goal by reducing per capita water use by at least 10 percent by December 31, 2015. This is an
implementing measure of the water sector of the AB 32 scoping plan, which will continue to be
implemented beyond 2020. Reductions in water consumption reduce the amount of energy
necessary, as well as associated emissions, to convey, treat, and distribute water; it also reduces
emissions from wastewater treatment.
19 The 15 percent figure is based on analyses completed by CARB. CARB’s analysis determined that per capita VMT
numbers that are 14.3 percent lower than the numbers under existing conditions or per capita VMT numbers
for light-duty vehicles that are approximately 16.8 percent lower than the numbers under existing conditions
are consistent with statewide GHG reduction targets. California Air Resources Board. 2019. 2017 Scoping Plan-
Identified VMT Reductions and Relationship to State Climate Goals. January. Available: https://ww2.arb.ca.gov/
sites/default/files/2019-01/2017_sp_vmt_reductions_jan19.pdf. Accessed: February 20, 2020.
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California Green Building Standards Code and Title 24 Updates
The California Green Building Standards Code (proposed Part 11, Title 24) was adopted as part of
the California Building Standards Code (24 California Code of Regulations). Part 11 established
voluntary standards that became mandatory under the 2010 edition of the code. These involved
sustainable site development, energy efficiency (in excess of California Energy Code requirements),
water conservation, material conservation, and internal air contaminants. The current energy
efficiency standards were adopted in 2019 and took effect on January 1, 2020.
4.7.3.4 Regional
Metropolitan Transportation Commission
The Metropolitan Transportation Commission (MTC) is the metropolitan planning organization for
the nine counties that make up the San Francisco Bay Area and the San Francisco Bay Area Air Basin
(SFBAAB), which includes the City of South San Francisco. The first per capita GHG emissions targets
for the SFBAAB were a 7 percent reduction by 2020 and a 15 percent reduction by 2035 compared
with 2005 levels. In 2013, MTC adopted an SCS as part of its RTP for the SFBAAB. This was known as
Plan Bay Area. The plan goes beyond the regional per capita targets, achieving 10 and 16 percent
reductions in per capita GHG emissions by 2020 and 2035, respectively. 20 On July 26, 2017, the
strategic update to this plan, known as Plan Bay Area 2040, was adopted by the Association of Bay
Area Governments (ABAG) and the MTC. As a limited and focused update, Plan Bay Area 2040 builds
upon the growth pattern and strategies developed in the original Plan Bay Area but with updated
planning assumptions that incorporate key economic, demographic, and financial trends since
2013.21 As required by SB 375, CARB updated the per capital GHG emissions reduction targets in
2018. The new targets, which will be addressed in MTC’s forthcoming RTPs, are a 10 percent per
capita GHG reduction by 2020 and 19 percent per capita reduction by 2035 compared with 2005
levels.22
Bay Area Air Quality Management District
As discussed in Section 4.2, Air Quality, of this draft environmental impact report (EIR), the Bay Area
Air Quality Management District (BAAQMD) is responsible for air quality planning within the
SFBAAB, including projects in the City. BAAQMD has adopted advisory emission thresholds to assist
CEQA lead agencies in determining the level of significance of a project’s GHG emissions, including
long-range plans (e.g., general plans, specific plans), which are outlined in the agency’s California
20 Metropolitan Transportation Commission and Association of Bay Area Governments. 2013. Plan Bay Area.
Adopted: July 18. Available: http://files.mtc.ca.gov/library/pub/28536.pdf. Accessed: June 8, 2020.
21 Metropolitan Transportation Commission and Association of Bay Area Governments. 2017. Plan Bay Area 2040.
Adopted: July 26. Available: http://2040.planbayarea.org/cdn/ff/buje2Q801oUV3Vpib-
FoJ6mkOfWC9S9sgrSgJrwFBgo/1510696833/public/2017-11/Final_Plan_Bay_Area_2040.pdf. Accessed:
February 7, 2020.
22 California Air Resources Board 2020c. SB 375 Regional Plan Climate Targets. Available:
https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-program/regional-plan-targets.
Accessed: February 7, 2020.
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Environmental Quality Act, Air Quality Guidelines.23 The BAAQMD CEQA Guidelines also outline
methods for quantifying GHG emissions as well as developing potential mitigation measures. As
discussed in Section 4.2, Air Quality, BAAQMD has also adopted air quality plans to protect the
climate, including the 2017 Clean Air Plan: Spare the Air, Cool the Climate.24 The 2017 Clean Air Plan
outlines feasible measures to reduce GHGs to 40 percent below 1990 levels by 2030 and 80 percent
below 1990 levels by 2050.
4.7.3.5 Local
South San Francisco General Plan
The 1999 City of South San Francisco (City) General Plan provides a vision for long-range physical
and economic development of the City, provides strategies and specific implementing actions, and
establishes a basis for judging whether specific development proposals and public projects are
consistent with the City’s plans and policy standards. The City General Plan contains an Open Space
and Conservation Element, which outlines policies related to habitat and biological resources, water
quality, air quality, GHG emissions, and historic and cultural resources. The City General Plan
includes the following policies, which are applicable to GHG emissions:
l Guiding Policy 7.3-G-4: Encourage land use and transportation strategies that promote the use
of alternatives to the automobile for transportation, including bicycling, bus transit, and
carpooling.
l Guiding Policy 7.3-G-5: Promote clean and alternative fuel combustion in mobile equipment and
vehicles.
l Implementing Policy 7.3-I-2: Use the City’s development review process and the CEQA
regulations to evaluate and mitigate the local and cumulative effects of new development on air
quality and GHG emissions.
l Implementing Policy 7.3-I-6: Periodically update the inventory of community-wide GHG
emissions and evaluate appropriate GHG emissions reduction targets, consistent with current
state objectives, statewide guidance, and regulations.
l Implementing Policy 7.3-I-7: Adopt and implement the City’s Climate Action Plan (CAP), which
will identify a GHG emissions reduction target and measures and actions to achieve the
reduction target.
l Implementing Policy 7.3-I-8: Evaluate and regularly report to City Council, or its designee, on
the implementation status of the CAP and update the CAP as necessary should the City find that
adopted strategies are not achieving anticipated reductions or to otherwise incorporate new
opportunities.
23 Bay Area Air Quality Management District. 2017b. California Environmental Quality Act, Air Quality Guidelines.
May. Available: https://www.baaqmd.gov/~/media/files/planning-and-
research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en. Accessed: January 7, 2020.
24 Bay Area Air Quality Management District. 2017a. Final 2017 Clean Air Plan. Adopted April 19. Available:
https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-air-plan/attachment-a_-
proposed-final-cap-vol-1-pdf.pdf?la=en. Accessed: January 6, 2020.
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l Implementing Policy 7.3-I-9: Promote land uses that facilitate alternative transit use, including
high-density housing, mixed uses, and affordable housing served by alternative transit
infrastructure.
l Implementing Policy 7.3-I-10: Facilitate energy efficiency in building regulations and
streamlined review processes, providing flexibility to achieve specified energy performance
levels and requiring energy efficiency measures as appropriate.
l Implementing Policy 7.3-I-11: Coordinate with the business community to encourage energy
efficiency in the city’s largest energy users while supporting economic growth objectives.
l Implementing Policy 7.3-I-12: Adopt guidelines, standards, and flexible regulations that promote
on-site renewable energy systems while strengthening South San Francisco’s economic
competitiveness.
l Implementing Policy 7.3-I-13: Encourage efficient, clean energy and fuel use through
collaborative programs, award programs, and incentives while removing barriers to the
expansion of alternative fuel facilities and infrastructure.
l Implementing Policy 7.3-I-14: Ensure that design guidelines and standards support operation of
alternative-fuel facilities, vehicles, and equipment.
Climate Action Plan
The Climate Action Plan (CAP), adopted in 2014, includes goals, policies, and strategies to reduce the
City’s GHG emissions, in compliance with AB 32 and SB 375. GHG reduction strategies identified in
the CAP include a development checklist to identify applicable plan measures for discretionary
projects. The City’s CAP was adopted in 2014, with the purpose of reducing GHGs community-wide
to achieve a reduction target of 15 percent below 2005 emission levels by 2020. As discussed in
Section 4.5, Energy, of this draft EIR, the City has identified GHG reduction measures to reduce GHG
emissions. Strategies include implementation of transportation demand management plans,
expanding active transportation alternatives, maximizing energy efficiency in the build
environment, developing a waste reduction strategy to increase recycling and reuse of materials,
and reducing water demand.25 The City’s CAP is currently being updated, as part of the General Plan
Update. The 2014 CAP remains active until completion and adoption of the new CAP.
Gateway Specific Plan
The Gateway Specific Plan covers the portion of the East of 101 Area Plan from east of the Caltrain
tracks to the eastern boundary of the parcels along the east side of Gateway Boulevard and the area
between Oyster Point Boulevard and Grand Avenue on the northern and southern boundaries. The
Specific Plan is “intended to provide for various commercial and research and development land
uses integrated by consistent development standards.” The Gateway Specific Plan includes the
following construction standards standard applicable to greenhouse gas emissions:
• Construction Standard 1(d): Energy Conservation. All Buildings shall be designed, insulated and
lighted in accordance with applicable federal and state energy conservation laws and
regulations.
25 City of South San Francisco. 2014. City of South San Francisco Climate Action Plan. Adopted: February 13.
Available: https://www.ssf.net/home/showdocument?id=1318. Accessed: January 7, 2020.
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Transportation Demand Management Ordinance
The City’s Transportation Demand Management (TDM) Ordinance identifies several required and
optional trip reduction measures for inclusion in a TDM Plan. The ordinance requires an annual
employee mode share survey of the project site to ensure that desired transportation mode shares
are achieved. Where the mode share target is not achieved, City officials may require program
modifications intended to increase alternative mode share or impose administrative penalties. TDM
measures implemented by the proposed project would support reductions in the number of trips
made by automobile and associated GHG emissions.
4.7.4 Impacts and Mitigation Measures
4.7.4.1 Significance Criteria
Based on Appendix G of the CEQA Guidelines, the proposed project would have a significant GHG
emissions impact if it would:
l Generate GHG emissions, either directly or indirectly, that may have a significant impact on the
environment;
l Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing
emissions of GHGs.
State CEQA Guidelines Section 15064.4 provides guidance to lead agencies for determining the
significance of environmental impacts pertaining to GHG emissions. State CEQA Guidelines Section
15064.4(a) states that a lead agency should make a good-faith effort that is based, to the extent
possible, on scientific and factual data to describe, calculate, or estimate the amount of GHG
emissions that would result from implementation of a project. State CEQA Guidelines Section
15064.4(b) also states that, when assessing the significance of impacts from GHG emissions, a lead
agency should consider (1) the extent to which the project may increase or reduce GHG emissions
compared with existing conditions, (2) whether the project’s GHG emissions would exceed a
threshold of significance that the lead agency has determined to be applicable to the project, and (3)
the extent to which the project would comply with regulations or requirements adopted to
implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.
The California Supreme Court’s decision in Center for Biological Diversity et al. v. California
Department of Fish and Wildlife (62 Cal.4th 204) confirmed that there are multiple potential
pathways for evaluating GHG emissions consistent with CEQA. Several air quality management
agencies throughout the State have also drafted or adopted various threshold approaches and
guidelines for analyzing GHG emissions in CEQA documents. Common threshold approaches include
(1) compliance with a qualified GHG reduction strategy, (2) numeric “bright-line” thresholds, (3)
efficiency-based thresholds, (4) performance-based reductions,26 and (5) compliance with
regulatory programs.
26 Performance-based thresholds are based on the percentage reduction from a projected future condition (e.g.,
reducing future business-as-usual emissions to meet the SB 32 target [40 percent below 1990 levels] through a
combination of state measures; project design features, such as features related to renewable energy; and
mitigation.
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BAAQMD’s CEQA Guidelines do not identify a GHG emission threshold for construction-related
emissions. Instead, BAAQMD recommends that GHG emissions from construction be quantified
and disclosed and that a determination regarding the significance of the GHG emissions be made
with respect to whether a project is consistent with the emissions reduction goals. The BAAQMD
further recommends incorporation of best management practices (BMPs) to reduce GHG
emissions during construction, as feasible and applicable. This approach is used to evaluate
construction-generated emissions.
The City has not adopted a qualified GHG reduction plan beyond 2020 (when the proposed project
would be constructed and operational), and tiering per State CEQA Guidelines Section 15183.5 is
not an applicable option to assess the proposed project’s GHG impacts.
BAAQMD has adopted a numeric threshold of 10,000 metric tons of CO2e for stationary-source
projects. This threshold is consistent with stationary-source thresholds adopted by other air
quality management districts throughout the State. The threshold level is intended to capture 95
percent of all GHG emissions associated with new permit applications for stationary-sources in
the air basin. It would do so by capturing only the large, significant projects, because permit
applications with emissions above the threshold of 10,000 metric tons of CO2e account for less
than 10 percent of all applications. The emergency generator included as part of the proposed
project would be a permitted source, and as such, the BAAQMD’s threshold of 10,000 metric tons
of CO2e is appropriate for analyzing the significance of emissions generated by the generator.
Impacts from stationary-source emissions would be considered less than significant if the
emissions total less than 10,0000 metric tons of CO2e.
In addition, BAAQMD has adopted a bright-line and efficiency-based threshold for land use
projects (1,100 metric tons of CO2e per year and 4.6 metric tons of CO2e/service population per
year,27 respectively)28 to evaluate a project’s total GHG emissions. However, these thresholds were
developed by BAAQMD in accordance with the reduction goals of the AB 32 2020 GHG reduction
targets. The proposed project would begin to be operational in 2021 and would operate entirely in
the post-2020 period. Thus, it is not appropriate to evaluate the project’s emissions relative to
2020 thresholds.29 Therefore, in absence of an applicable threshold, this analysis references the
proposed project’s GHG emissions relative to BAAQMD’s thresholds adjusted for 2021 (1,056
annual metric tons of CO2e/year) for information purposes and to contextualize the proposed
project’s GHG emissions. Ultimately, the analysis examines the proposed project’s consistency
with applicable best management practices and design features required by regulations (e.g., Title
24, CalGreen, etc.), and guidance from state agencies (e.g., CARB, OPR, etc.) that pertains to
achieving GHG reduction targets. Such an approach is recognized by the Supreme Court as an
acceptable pathway for evaluating project-level GHG emissions under CEQA (62 Cal.4th 204). The
proposed project is assumed to be operational by 2021. The State’s 2030 target has been codified
27 Service population refers to the total number of residents and/or employees. For the proposed project, the
service population for the entire project site (701 Gateway and 751 Gateway) is 1,181 employees.
28 Bay Area Air Quality Management District. 2017b. California Environmental Quality Act, Air Quality Guidelines.
May. Available: https://www.baaqmd.gov/~/media/files/planning-and-
research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en. Accessed: January 7, 2020.
29 These thresholds do not account for GHG emissions reductions from new development post-2020 and are not
tailored to the proposed project.
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in law through SB 32 and the 2017 climate change scoping plan30 that was adopted to meet this
2030 target. Therefore, 2030 marks the next statutory statewide milestone target that would be
applicable to the proposed project.
The analysis focuses on the 2030 target and the plans, policies, and regulations adopted pursuant to
achieving 2030 reductions. Emissions generated in 2021 are used as an indicator for long-term
emissions reduction progress and are evaluated as they relate to the proposed project’s impacts on
the State’s long-term GHG emission reduction targets. More specifically, best management practices
and project design features stipulated by Title 24, California Department of Water Resources Model
Water Efficient Landscape Ordinance, the 2019 California Green Building Standards Code, and
CARB’s 2017 scoping plan, for instance, could be utilized to show compliance with performance-
based standards needed to fulfill the statewide goal for reducing GHG emissions.
The proposed project’s compliance with best management practices, design features, and regulatory
plans and programs adopted by CARB and other State agencies is therefore used to discuss the
significance of the proposed project’s GHG emissions. While the regulatory framework to achieve
long-term (post-2030) emissions reductions is in its infancy, many of the best management
practices, design features, and programs discussed in the sections below are likely to be carried
forward or have already been adopted with post-2030 requirements (e.g., Renewable Portfolios
Standard, Title 24, etc.). Accordingly, evaluating consistency with best management practices, design
features, and programs and relevant guidance published by agencies such as CARB and OPR for the
reduction of long-term emissions is therefore considered in the analysis of the proposed projects
emissions.
l Mobile sources: CARB’s 2017 scoping plan recognizes that, although vehicle technologies and
low-carbon fuels will continue to reduce transportation sector emissions, VMT reductions are
necessary to achieve California’s long-term GHG emissions reduction target. Recent CARB
analysis demonstrates that a 16.8 percent reduction in light-duty VMT per service population by
2050 (compared to a 2015–2018 average) would be needed statewide to meet long-term
climate change planning goals through 2050.31 This reduction target is consistent with recent
OPR guidance32 issued in SB 743, as discussed in Section 4.7.3, Regulatory Framework, and
Section 4.9, Transportation and Circulation. Construction of the proposed project would
commence in 2020 and be operational in 2021, if related entitlements are approved by the City.
Accordingly, use of CARB’s threshold of a 16.8 percent reduction in light-duty VMT per service
population for mobile-source emissions is applicable to the proposed project. Mobile-source
emissions would be considered less than significant if the proposed project achieves a per
service population VMT reduction of at least 16.8 percent (compared to a 2015–2018 average).
In addition to VMT reductions, compliance with regulatory programs (e.g., AB 1493, LCFS, SB
743, and SB 375) would also be required to reduce statewide mobile GHG emissions to a less-
than-significant impact.
30 California Air Resources Board. 2019. 2017 Scoping Plan – Identified VMT Reductions and Relationship to State
Climate Goals. January. Available: https://ww2.arb.ca.gov/sites/default/files/2019-
01/2017_sp_vmt_reductions_jan19.pdf. Accessed: February 20, 2020.
31 Ibid.
32 Governor’s Office of Planning and Research. 2018. Technical Advisory on Evaluating Transportation Impacts in
CEQA. December. Available: http://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf. Accessed: February
20, 2020.
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l Energy, water, waste, area, and land sources. CARB’s 2017 scoping plan, which relies
heavily on state programs (e.g., Title 24 and SB 100), outlines the strategies required to
reduce statewide GHG emissions and achieve California’s SB 32 reduction target.33 Projects
that implement applicable strategies from the 2017 scoping plan and other best management
practices and design features outlined in other programs would be consistent with the State’s
GHG reduction framework and requirements for these sectors. Accordingly, a sector-by-
sector review of the respective project features and sustainability measures included in the
proposed project is provided to evaluate consistency with best management practices, design
features, plans, and policies. This assessment also considers recent OPR guidance34 related to
long-term reductions in statewide emissions. Accordingly, impacts from energy, water,
waste, area, and land use source emissions would be considered less than significant if the
proposed project is consistent with all applicable best management practices, design
features, strategies and supporting regulations and guidance.
4.7.4.2 Approach to Analysis
Construction Emissions
The proposed project would generate construction-related GHG emissions from the exhaust of
mobile and stationary construction equipment, exhaust of employees’ vehicles and haul trucks,
electricity consumption, and tree removal. GHG emissions were estimated using the California
Emissions Estimator Model (CalEEMod), version 2016.3.2. The construction schedule, details
regarding equipment operations, trip numbers and lengths, and material quantities were
provided by the project sponsor. Annual construction emissions were estimated using these
project-specific details. The construction modeling inputs and CalEEMod outputs are provided in
Appendix B of this draft EIR.
Operational Mobile-Source Emissions
GHG impacts from motor vehicles traveling to and from the project site were evaluated using
CARB’s EMFAC2017 emissions model (version 1.02) and traffic data provided by Fehr & Peers.35
The existing office building at 701 Gateway Boulevard would remain on the site. Therefore,
operational mobile-source emissions associated with the office building at 701 Gateway
Boulevard were estimated and presented under existing (2019) and future conditions (2021).36
33 California Air Resources Board. 2017. California’s 2017 Climate Change Scoping Plan. November. Accessed:
https://ww3.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf. Accessed: February 20, 2020.
34 California Air Resources Board. 2019. 2017 Scoping Plan-Identified VMT Reductions and Relationship to State
Climate Goals. January. Available: https://ww2.arb.ca.gov/sites/default/files/2019-01/2017_sp_vmt_reductions
_jan19.pdf. Accessed: February 20, 2020.
35 Hawkins, Mike. Fehr & Peers. March 13, 2020—email to Jessica Viramontes: 751 Gateway Updated
Transportation Materials.
36 There are no emission sources associated with the existing surface parking lot; therefore, there are no
emissions associated with the lot under the existing condition. Emissions presented for the existing condition
represent those from the office building at 701 Gateway Boulevard.
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To determine GHG emissions (i.e., from vehicle movement/travel), the number of daily
employees on the project site and a VMT per capita conversion factor, both provided by Fehr &
Peers, were used estimate total VMT with and without the proposed project. GHG emissions from
vehicle exhaust were calculated by multiplying the VMT estimates by the appropriate emission
factors from EMFAC2017 with SAFE Vehicle Rule adjustments per CARB.
Daily trips for the proposed project were also provided by Fehr & Peers and used to estimate a
per employee trip generation rate, which was used to estimate existing daily trips associated
with the existing building at 701 Gateway Boulevard. The number of daily employee trips
associated with the proposed project assumes a mode share consistent with the City/County
Association of Governments of San Mateo County (C/CAG) travel demand model and recent
analysis for other similar projects within the City and the region. The number of daily trips was
calculated to quantify vehicle-process emissions, such as emissions generated from vehicle
starts, running losses, etc. Process GHG emissions were then calculated by multiplying the
number of daily trips by the appropriate process-specific GHG emission factors from
EMFAC2017. The running exhaust emissions and process emissions were combined to quantify
total operational GHG emissions from the project’s use of vehicles. The EMFAC0217 emission
factors and traffic data used in this analysis are provided in Appendix B of this draft EIR.
Operational Area, Energy, Stationary, Water, and Waste Emissions
Area, energy, stationary, water, and waste emissions were estimated using CalEEMod (version
2016.3.2). Landscaping equipment, including gasoline-powered equipment (e.g., trimmers,
mowers), is the primary area source of GHG emissions. Calculations of area-source emissions rely
on CalEEMod’s default assumptions, which represent a conservative estimate of equipment
usage, based on the square footage of the new building space. The combustion of natural gas for
building heating and hot water, as well as the use and generation of electricity, is the primary
energy source of GHG emissions. Stationary sources include one emergency generator. Water
consumption results in indirect GHG emissions from the conveyance and treatment of water.
Waste generation results in fugitive CH4 and N2O emissions from the decomposition of organic
matter.
Emissions were quantified for existing (2019) and 2021 conditions with the proposed project.
Similar to mobile-source emissions (discussed above), area-, energy-, and stationary-source
emissions were also estimated for the existing office building at 701 Gateway Boulevard. Annual
energy (e.g., electricity and natural gas) consumption and annual water consumption for the
existing office building at 701 Gateway Boulevard and the proposed project were provided by the
project sponsor and used to model energy and water emissions.37 The project sponsor also
provided details on the proposed generator to be located on the project site. The 2021 modeling
reflects implementation of state measures to reduce GHG emissions (e.g., SB 100, Pavley).
Quantifiable features, consistent with the proposed project, including the installation of low-flow
fixtures, were incorporated into the CalEEMod model. The net change in the number of trees on
the project site was also modeled to account for changes to sequestration. The CalEEMod output
files are provided in Appendix B of this draft EIR.
37 Muchow, Chase. RMW Architecture & Interiors. March 2, 2020—email to Jessica Viramontes: 751 Gateway –
Priority 1 and 2 Follow-Up.
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4.7.4.3 Impact Evaluation
Impact GHG-1a: The proposed project would not generate GHG emissions, either directly or
indirectly, that may have a significant impact on the environment during construction. (Less
than Significant with Mitigation)
Construction associated with the proposed project would result in the temporary generation of GHG
emissions. Emissions would originate from the exhaust of mobile and stationary construction
equipment as well as employees’ vehicles and haul trucks. Construction activities for the proposed
project would include demolition of a surface parking lot, construction of a new building, various
site improvements, and the provision of utility infrastructure. These activities would require mobile
and stationary construction equipment as well as on-road vehicles, such as haul trucks for
demolition debris and vendor trucks for deliveries. Site grading and excavation would also be
required for the building foundation, utilities, and landscaping. Estimated construction GHG
emissions are presented in Table 4.7-3. The table shows that project construction would generate
approximately 1,335 metric tons of CO2e over the 18-month construction period.
Table 4.7-3. Estimated Construction GHG Emissions from the Proposed Project (metric tons)
Construction
Year CO2 CH4 N2O CO2ea
2020 843 < 1 < 1 845
2021 488 < 1 < 1 490
Totalb 1,331 0 0 1,335
Source: See Appendix B of this draft EIR for CalEEMod model outputs and construction energy calculations.
Notes:
a Emissions represent the sum of emissions from the CalEEMod construction output and energy consumption
(approximately 52,000 kilowatt-hours per year) during construction.
b Totals may not add up because of rounding.
For a typical building, emissions from concrete production are generated to create the materials that
would be required to construct new buildings. As a project design feature, the proposed project
would utilize no-carbon emission concrete. These emissions associated with concrete production
are lifecycle emissions38, however, are not required to be analyzed under CEQA. The project’s use of
no-carbon emission concrete would result in lower total emissions for the project and is consistent
with state goals to reduce GHG emissions, but because life-cycle emissions are outside of the scope
of CEQA, the emissions benefits were not quantified.
As described above, BAAQMD has not established a quantitative threshold for assessing
construction-related GHG emissions. Rather, the air district recommends evaluating whether
construction activities would conflict with statewide emissions reduction goals and recommends
implementing feasible BMPs. If a project does not implement feasible BMPs, it is anticipated that it
would conflict statewide emission goals, and construction-related GHG emission impacts would be
significant. Therefore, Mitigation Measure GHG-1, Require Implementation of BAAQMD-
38 Lifecycle emissions are those that are generated during the manufacturing process, for example, to turn raw
resources into buildings materials.
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recommended Construction BMPs, would be implemented to avoid any conflict with statewide
emissions reduction goals. Consequently, the impact from construction-related GHG emissions
would be less than significant with mitigation.
Mitigation Measure GHG-1: Require Implementation of BAAQMD-recommended
Construction BMPs
The project sponsor shall require its contractors, as a condition in contracts (e.g., standard
specifications), to reduce construction-related GHG emissions by implementing BAAQMD’s
recommended BMPs as set forth in BAAQMD’s 2017 CEQA Guidelines, including (but not limited
to) the following measures:39
l Ensure alternative-fuel (e.g. biodiesel, electric) construction vehicles/equipment make up at
least 15 percent of the fleet;
l Use local building materials (at least 10 percent) sourced from within 100 miles of the
planning area; and
l Recycle and reuse at least 50 percent of construction waste or demolition materials.
The project sponsor shall submit evidence of compliance to the City prior to the start of
construction.
Impact GHG-1b: The proposed project would generate GHG emissions, either directly or
indirectly, that may have a significant impact on the environment during operation.
(Significant and Unavoidable with Mitigation)
Operation of the proposed project would generate direct and indirect GHG emissions. Sources of direct
emissions include vehicle trips, emergency generators, natural gas combustion, and landscaping
activities. Indirect emissions would be associated with electricity consumption, waste and wastewater
generation, and water use. Operational GHG emissions were evaluated under existing-year (2019) and
proposed project conditions (2021). The analysis includes emissions benefits from statewide GHG
emissions reduction programs (e.g., SB 100) as well as quantifiable sustainability measures, including
the installation of low-flow fixtures, incorporated into the project design. Table 4.7-4 presents the
proposed project’s net annual GHG emissions, which is the difference between proposed project
conditions (2021) and existing emissions (2019), and total GHG emissions.
As shown in Table 4.7-4, the proposed project would result in a net annual increase of 4,338 metric
tons of CO2e, exceeding the adjusted threshold of 1,056 annual metric tons of CO2e discussed above.
Though comparisons with BAAQMD’s adjusted threshold are discussed here for informational
purposes, an analysis of the proposed project’s consistency with best management practices and
design features outlined in regulatory plans and programs aimed at meeting the state’s long term
GHG reduction targets was completed to determine whether the proposed project would generate
significant levels of GHG emissions. The following sections present this analysis.
39 Bay Area Air Quality Management District. 2017b. California Environmental Quality Act, Air Quality Guidelines.
May. Available: https://www.baaqmd.gov/~/media/files/planning-and-
research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en. Accessed: January 7, 2020.
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Area Emissions
As shown in Table 4.7-4, annual emissions from the proposed project associated with area sources
would amount to less than 1 metric ton of CO2e. The proposed landscaping would include trees,
shrubs, and biotreatment plantings as opposed to grass areas, which would minimize the routine
use of mowers and other landscaping equipment.
There are no relevant measures in the scoping plan for landscaping equipment. Although a
transition away from fossil-fueled equipment would be needed to achieve carbon neutrality by
2045, the scoping plan did not assume all-electric landscaping equipment in the 2030 reduction
analysis. The proposed landscaping would reduce landscaping emissions compared with emissions
from buildings with grass areas. This is consistent with the scoping plan’s overall goal of reducing
emissions from fossil-fueled landscaping equipment.
Energy Emissions
As shown in Table 4.7-4, annual building energy emissions from the proposed project would amount
to approximately 655 metric tons of CO2e. OPR’s 2018 CEQA and Climate Change Advisory notes that
a land use development project that “achieves applicable building energy efficiency standards, uses
no natural gas or other fossil fuels, and includes Energy Star appliances, where available, may be
able to demonstrate a less-than-significant greenhouse gas impact associated with project
operation.” Although OPR recommends that new buildings should avoid use of fossil fuels, the
scoping plan does not assume all-electric buildings in the 2030 reduction analysis. Rather, the
scoping plan assumes new gas appliances will be high-efficiency units.
The proposed project would consume both electricity and natural gas. Electricity-related emissions
would be mitigated through compliance with the scoping plan through SB 100. Per SB 100,
electricity generation will become progressively less carbon intensive until 100 percent reliance on
renewable energy is achieved in 2045. In addition, the proposed project would install Energy Star
appliances and meet the United States Green Building Council’s Leadership in Energy and
Environmental Design (LEED) requirements for Gold certification as well as the International WELL
and Fitwel Building Institute Standards. Although the proposed project would allow natural gas
appliances and heaters, all units would meet high-efficiency standards, consistent with the
assumptions and emissions reduction requirements of the scoping plan for 2030. The proposed
project would also install and include solar-ready rooftop connectivity for future installation of
photovoltaic panels. This is consistent with the scoping plan’s overall goal of reducing energy
emissions from buildings that consume fossil fuels.
Land Use Emissions
The proposed project would retain 52 trees, remove 175 trees and plant 112 trees, for a net tree
loss of 63 trees. Younger trees typically sequester more CO2e compared to older and more mature
trees.40 However, additional sequestration from newer trees would be offset by the potential net
40 Mongabay. 2019. Tall and Old or Dense and Young: Which Kind of Forest Is Better for the Climate? May. Available:
https://news.mongabay.com/2019/05/tall-and-old-or-dense-and-young-which-kind-of-forest-is-better-for-the-
climate/#:~:text=While%20young%20forests%20tend%20to,rate%20accelerates%20as%20it%20ages.&text=A%2
0study%20found%20the%20logging,the%20world's%20dirtiest%20coal%20plant. Accessed: July 21, 2020.
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Table 4.7-4. Estimated GHG Emissions from Operation of the Proposed Project (metric tons/year)
Condition/Source CO2 CH4 N20 CO2e % CO2e
Existing (2019)
701 Gateway (existing office building) and 751 Gateway (existing parking lot)
Area Sources <1 <1 <1 <1 0%
Energy Sources 398 <1 <1 401 14%
Mobile Sources 2,331 <1 <1 2,360 82%
Stationary Sources 39 <1 <1 39 1%
Waste Generation 32 2 <1 80 3%
Water Consumption 2 <1 <1 4 <1%
Totala 2,802 2 0 2,884 100%
Proposed Project (2021)
701 Gateway (existing office building)
Area Sources < 1 < 1 < 1 < 1 < 1%
Energy Sources 382 < 1 < 1 385 5%
Mobile Sources 2,229 < 1 < 1 2,256 31%
Stationary Sources 39 < 1 < 1 39 1%
Waste Generation 32 2 < 1 80 1%
Water Consumption 2 < 1 < 1 4 < 1%
751 Gateway (proposed R&D and office building)
Area Sources < 1 < 1 < 1 <1 < 1%
Energy Sources 649 < 1 < 1 655 9%
Mobile Sources 3,619 < 1 < 1 3,662 51%
Stationary Sources 39 < 1 < 1 39 1%
Waste Generation 19 1 < 1 48 1%
Water Consumption 3 < 1 < 1 7 < 1%
Totala,b 7,006 3 < 1 7,168 100%
Net Increase with Proposed Project
2021 v. Existinga, b, c 4,292
Land Use Emissions/Sequestration Loss (Proposed Tree Removal)c 46
Total b 4,338
Source: See Appendix B of this draft EIR.
Notes:
CO2 = carbon dioxide; CH4 = methane; N20 = nitrous oxide; CO2e = carbon dioxide equivalent
a The number of existing parking spots within the project site was revised from 558 to 564 subsequent to the GHG
analysis. Parking lots generate limited GHG emissions; therefore, the six additional parking spots would not
substantially change the numeric values presented in this table.
b Totals may not add up because of rounding.
C The proposed project would result in a net loss of 63 trees at the project site, resulting in losses in carbon
sequestration and a net carbon increase in the atmosphere. The CalEEMod model assumes loss of new trees, which
sequester more CO2 than older trees. As such, land use emissions presented are conservative. Implementation of
Mitigation Measure GHG-2 would result in a net loss of 19 of trees, which would reduce land use emissions and
sequestration loss. As such “Total” emissions presented are conservative.
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release of carbon from the removal of the replaced trees.41 Therefore, it is conservatively assumed
that the loss in trees would result in the loss of some carbon sequestration (up to 46 metric tons of
CO2e)42.There are no relevant measures in the scoping plan or explicit regulatory requirements
related to tree planting. Although the magnitude of emissions generated by the net loss in trees
within the project site would be relatively minor, it would not be consistent with the scoping plan’s
overall goal of avoiding losses in carbon sequestration.
Mobile-Source Emissions
As shown in Table 4.7-4, annual mobile-source emissions from the proposed project would
amount to approximately 3,662 metric ton of CO2e. This figure is driven primarily by the
additional VMT expected as a result of the proposed project. The proposed project would install
25 electric vehicle (EV) charging spots per CalGreen. As discussed in Section 4.9, Transportation
and Circulation, of this draft EIR, the proposed project would increase VMT per service population
relative to existing conditions (2019) and would not meet the 16.8 percent VMT per service
population reduction target recommended by CARB to be achieved by 2030; therefore, the
proposed project would conflict with the State’s long-term emissions reduction trajectory.
Stationary-Source Emissions
As shown in Table 4.7-4, stationary sources (i.e., the proposed emergency generator) would
generate approximately 39 metric tons of CO2e annually. This net increase is below BAAQMD’s
stationary-source threshold of 10,000 metric tons of CO2e per year.
Waste Emissions
As shown in Table 4.7-4, annual waste emissions from the proposed project would amount to
approximately 48 metric tons of CO2e. The proposed project would install communal receptacles
for trash/recyclables/compostables and provide tenants with bins for separating waste. In
addition, the proposed project would have dedicated areas where recyclable materials from the
building would be collected and stored. These areas would be accessible for both waste haulers
and tenants. Recyclable materials include mixed paper products, corrugated cardboard, glass,
plastics, and metals. The proposed project would also facilitate the collection, storage, and
disposal of batteries, mercury-containing lamps, and electronic waste. These features are
consistent with the scoping plan’s overall goal of reducing waste emissions and its specific
strategy to avoid landfill CH4 emissions by reducing the disposal of landfilled waste and organics.
These features would support and comply with the mandatory recycling requirement in AB 341
and support the State’s recycling goal.
Water Emissions
As shown in Table 4.7-4, annual emissions from the proposed project’s water use would amount to
approximately 7 metric tons of CO2e. The proposed project includes several water conservation
features. For example, the proposed project would achieve LEED Gold certification or equivalent and
41 Trinity Consultants. 2017. Appendix A, Calculation Details for CalEEMod. October. http://www.aqmd.gov/docs/
default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6. Accessed: July 29, 2020.
42 The CalEEMod model assumes loss of new trees, which sequester more CO2 than older trees. As such, estimated
land use emissions are conservative.
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install low-flow fixtures. Outdoor water conservation measures would include the installation and
maintenance of water-efficient landscaping with low-usage plant material to minimize irrigation
requirements. Furthermore, the proposed project would comply with all applicable water
conservation (indoor and outdoor) measures, including Title 24, Part 6, California Energy Code
baseline standard requirements for energy efficiency, based on the 2019 Energy Efficiency Standards,
California Department of Water Resources Model Water Efficient Landscape Ordinance, and the 2019
California Green Building Standards Code, commonly referred to as CALGreen. These features are
consistent with the scoping plan’s overall goal of reducing water emissions and serve to support
ongoing regulatory programs (e.g., SB X7-7 Title 24) that aim to reduce GHG emissions associated with
conveying and distributing water to ultimately achieve climate neutrality.
Conclusion
The proposed project’s sustainability measures represent a robust suite of strategies that are
consistent with applicable policies, design features, and best management practices from the scoping
plan and regulatory programs for the area, energy, waste, and water sectors. Stationary-source
emissions would be below BAAQMD’s stationary source threshold.
The proposed project would result in a net loss in the number of trees on the project site, which would
result in losses in carbon sequestration and a relatively minor carbon increase in the atmosphere.
Implementation of Mitigation GHG-2, Operational GHG Reduction Measures, would plant 44 additional
trees on the project site’s existing parking lots. However, there would still a net tree loss of 19 trees. In
addition, the proposed project would not achieve the 16.8 percent VMT per service population
reduction target. The proposed project would be subject to regulatory programs related to fuel and
vehicle efficiency as well as vehicle electrification. Implementation of Mitigation Measure GHG-2,
Operational GHG Reduction Measures would lead to installation of 28 more EV chargers than required
by the 2019 Building Code. This measure would incentivize the use of electric vehicles, but the
associated emission reductions would depend on individual choices to purchase electric vehicles and
therefore were not quantified. Implementation of Mitigation Measure TR-1, as discussed in Section
4.9, Transportation and Circulation, of this draft EIR, would contribute a fair share toward funding the
design and construction of off-site improvements to support the proposed project’s first- and last-mile
transit connection strategies, which are necessary to support reductions in the number of trips made
by automobile. These improvements include fair-share contributions toward the City’s cost of
upgrading sidewalks, upgrading and extending bicycle and pedestrian pathways, providing a more
direct connection to on-street shuttle stops, participating in first/last shuttle programs, and striping
unmarked crosswalks. However, the lead agency cannot determine with certainty that implementation
of Mitigation Measures GHG-2 and TR-1 would reduce the proposed project’s VMT to a less-than-
significant level because the mitigation measure’s effectiveness cannot be precisely quantified. Given
that the proposed project already includes a robust TDM plan, financial support for last mile
improvements, and other GHG reduction features, such as installation of EV chargers, there are no
other feasible mitigation measures.
Consequently, although emissions from the stationary-source, area, energy, waste, and water sectors
would generally be consistent with BAAQMD’s stationary threshold or the scoping plan, applicable
guidance from relevant agencies, and regulatory programs, policies, design features, and best
management practices, land use emissions from the proposed project would not be consistent with
the scoping plan with implementation of mitigation. Mobile-source emissions, with implementation
of mitigation, would also not reduce GHG emissions to ensure consistency with the State’s goals.
Therefore, operational GHG impacts would be significant and unavoidable with mitigation.
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Mitigation Measure GHG-2: Operational GHG Reduction Measures
The project sponsor shall:
l Plant 44 additional trees on existing surface parking lots; and
l Install 28 more electric vehicle (EV) charging spots than required by the 2019 Building
Code.
Impact GHG-2: The proposed project would conflict with an applicable plan, policy, or
regulation adopted for the purpose of reducing the emissions of GHGs. (Significant and
Unavoidable with Mitigation)
SB 32 and CARB’s 2017 Scoping Plan
SB 32 outlines the State’s GHG emissions reduction targets for 2030 and builds on the reduction
targets adopted by AB 32. The proposed project includes many GHG reduction features and would
not impede the State from reaching these goals. In 2008 and 2014, CARB adopted the scoping plan
and first update, respectively, as a framework for achieving AB 32. The scoping plan and first update
outlined a series of technologically feasible and cost-effective measures to reduce statewide GHG
emissions. CARB adopted the climate change scoping plan in November 2017 as a framework for
achieving the 2030 GHG reduction goal described in SB 32. There is no state plan for addressing GHG
reductions beyond 2030. Because this analysis is focused on emissions in 2030, it addresses the
project’s operational emissions (construction would be completed by 2021).
Based on CARB’s 2017 scoping plan, many of the reductions needed to meet the 2030 target will
come from state regulations, including cap-and-trade requirements, the requirement for additional
renewable energy sources in California’s energy supply, updates to Title 24, and increased emissions
reduction requirements for mobile sources. The 2017 scoping plan indicates that reductions will
need to come in the form of changes pertaining to vehicle emissions and mileage standards, changes
related to sources of electricity, and increased energy efficiency at existing facilities as well as state
and local plans, policies, or regulations to lower GHG emissions relative to business-as-usual
conditions. The 2017 scoping plan carries forward GHG reduction measures from the first update as
well as new potential measures to help achieve the State’s 2030 target across all sectors of the
California economy, including transportation, energy, and industry.
The 2017 scoping plan recommends prioritizing on-site GHG reduction features in the project’s
region. Appendix B to the 2017 scoping plan includes examples of on-site project design features
and mitigation measures that may be feasible to minimize GHG emissions from land use
development projects. The proposed project is generally consistent with the on-site project design
features and mitigation measures outlined in Appendix B to 2017 scoping plan, reducing GHG
emissions and associated impacts from area, energy, water, and waste source. For instance, the
proposed project would reduce area emissions by minimizing the use of fossil fueled landscaping
equipment; reduce energy emissions by installing Energy Star and high efficiency appliances, and
meeting LEED Gold or equivalent certification requirements, the international WELL and Fitwel
Building Institute Standards; reduce waste emissions by reducing the disposal of landfilled waste
and organics and mandating recycling; reduce water emissions by achieving LEED Gold
certification or equivalent, installing low-flow fixtures, installing water-efficient landscaping with
low-usage plant material, and supporting ongoing water regulatory programs. These reductions
would help the State meet its GHG reduction goals. As discussed above, stationary-source emissions
would be below BAAQMD’s stationary-source threshold.
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Implementation of Mitigation GHG-2 would reduce the proposed project’s net tree loss by planting
additional trees on the project site’s existing parking lots, but would still result in losses in overall
carbon sequestration. Implementation of an aggressive TDM program, Mitigation Measure GHG-2
(i.e., EV charging stations) and Mitigation Measure TR-1 would reduce mobile-source emissions
during operation but would not reduce emissions enough to meet the 16.8 percent VMT per service
population reduction target developed by CARB. As discussed in the transportation chapter of this
EIR and above, there are no additional, feasible VMT reduction measures. Therefore, the GHG
impacts of the proposed project would be significant and unavoidable with mitigation because
the project would not be consistent with every scoping plan policy even though it would help the
state reduce GHG emissions because it incorporates GHG reduction measures beyond those required
by law.
SB 375 and Plan Bay Area
Climate protection and transportation system effectiveness are two of seven goals addressed in
MTC’s Plan Bay Area (2013 and 2040). Plan Bay Area provides a long-range framework for
minimizing transportation impacts on the environment, improving regional air quality, protecting
natural resources, and reducing GHG emissions. The plan supports smart growth principles,
promotes infill development, and proactively links land use, air quality, and transportation needs in
the region. Plan Bay Area is consistent with SB 375, which requires MTC to adopt an SCS that
outlines policies to reduce per service population GHG emissions from automobiles and light trucks.
The SCS policies include a mix of strategies that encourage compact growth patterns, alternative
transportation, transit, mobility and access, network expansion, and transportation investment.
Implementation of the SCS is intended to improve the efficiency of the transportation system and
promote a variety of land use types throughout the Bay Area that meet market demands in a
balanced and sustainable manner. As discussed under Impact GHG-1b, the proposed project would
be built around the concept of sustainability and would include green building techniques as well as
energy efficiency, water conservation, and waste reduction measures.
The proposed project would allow development that would accommodate forecast growth within the
project site. Consistent with MTC goals, the proposed project would promote a transit-/pedestrian-
/bicycle-friendly environment. Specifically, the proposed project would improve connectivity with
employee shuttles through construction of a new shuttle stop on the project site, bicycle parking, and
charging spaces for electric vehicles. These features would support alternative transportation within
the project site, which could help reduce per service population GHG emissions from passenger
vehicles, consistent with Plan Bay Area. However, as discussed under Impact GHG-1b, the proposed
project would not meet the VMT per service population reduction target developed by CARB.
Implementation of Mitigation Measure TR-1 would reduce mobile-source emissions during
operation but would not reduce emissions enough to meet the reduction target. As such, it is
conservatively assumed that the proposed project would not meet the 2035 per capita GHG per SB
37543. This may affect the ability for the region to meet its SB 375 reduction target. Therefore, the
proposed project is conservatively assumed to be inconsistent with the goals of SB 375 and Plan Bay
Area, and this impact would be significant and unavoidable with mitigation.
43 California Air Resources Board. 2020c. SB 375 Regional Plan Climate Targets. Available:
https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-program/regional-plan-targets.
Accessed: February 7, 2020.
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Consistency with Other State Regulations
Systemic changes will be required at the State level to achieve California’s future GHG reduction
goals. Regulations, such as future amendments to the LCFS, future updates to the State’s Title 24
standards, and implementation of the State’s SLCP Reduction Strategy, including forthcoming
regulations for composting and organics diversion, will be necessary to attain the magnitude of
reductions required for the State’s goals. The proposed project would be required to comply with
these regulations in new construction (in the case of updated Title 24 standards) or directly affected
by the outcomes (i.e., vehicle trips and energy consumption would be less carbon intensive because
of statewide compliance with future LCFS amendments and increasingly stringent RPS). Therefore,
for the foreseeable future, the proposed project would not conflict with any other state-level
regulations pertaining to GHGs in the post-2020 era, and this impact would be less than significant.
4.7.4.4 Cumulative Impacts
Climate change is a global problem, and GHGs are global pollutants, unlike criteria air pollutants
(such as ozone precursors), which are primarily pollutants of regional and local concern. Given the
long atmospheric lifetimes, GHGs emitted by various sources worldwide accumulate in the
atmosphere. No single emitter of GHGs is large enough to trigger global climate change on its own.
Rather, climate change is the result of the individual contributions of countless past, present, and
future sources. Therefore, GHG impacts are inherently cumulative, and the analysis above is
inclusive of cumulative impacts.