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71 Prior EIR Determination Effect Peculiar to Project Site? New Significant Effect? New Significant Off-Site, Cumulative Impact? New Information, More Severe Adverse Impact? DTPP EIR DTPP Plan-Wide Amendments SEIR Focused GPU EIR VIII. GREENHOUSE GAS EMISSIONS – Would the project: a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? LTS SU LTS No No No No b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Not Addressed SU LTS No No No No c) Expose people or structures to a significant risk of loss, injury or death involving flooding caused by sea level rise resulting from global climate change? SU LTS Not Addressed No No No No Documentation: Commercial Component: a. The DTPP program EIR identified a less than significant impact with respect to generation of greenhouse gas (GHG) emissions that could have a significant impact on the environment. The analysis found that GHG emissions generated by the DTPP would be less than the emissions per service population threshold recommended by the BAAQMD at the time. No significant impact was identified and hence, no mitigation was required. The DTPP Plan-Wide Amendments program SEIR (pp. 13-35 through 13-39) explained changes that have occurred since the 2010 DTPP program EIR to applicable plans, policies, and regulations to reduce greenhouse gas emissions. The DTPP Plan-Wide Amendments program SEIR explained how the DTPP Plan-Wide Amendments project would be substantially consistent with and would not conflict with these current plans, policies, and regulations.12 The DTPP Plan-Wide Amendments program SEIR also provided analysis addressing two major direct sources of GHG emissions – building energy use and energy use related to vehicle miles travelled (VMT) – and included Mitigation Measure CC-1 (“Enforce No Natural Gas Requirement and Require Compliance with EV Requirements in CALGreen Tier 2”). Mitigation Measure CC-1 requires project compliance with City Reach Code “all electric” and electric vehicle (EV) requirements (or the most recently adopted CALGreen Code Tier 2 EV standards) in effect at the time that a building permit application is filed. However, the DTPP Plan-Wide Amendments program SEIR (p. 13-39) concluded that “full implementation of all electric building development may not be feasible because projects may qualify for exceptions to the all-electric requirements” (such as affordable housing projects, projects with commercial kitchens, and City- designated Research and Development Laboratory space). Therefore, this impact was determined to be significant and unavoidable. In November 2022, the City Reach Codes were amended (Ordinance No. 2521). These amendments revised the previous City amendments to the Green Building Standards Code; based on these amendments, the Reach Code “no natural gas” standard applied only to newly constructed buildings or new construction; in addition, the Reach Code was amended to provide for an applicant to request an exception to the all-electric building requirement by establishing, with substantial evidence, that the all-electric standard is infeasible for the project “due to exceptional or extraordinary circumstances particular to the project.” Due to a recent court decision affecting Reach Codes statewide, the City has suspended enforcement of the Reach Codes. As discussed in item VI, Energy, the applicant does not propose use of natural gas and has confirmed that the building would be “all-electric”; e.g., no natural gas would be used for HVAC, domestic hot water, or cooking. SEIR Mitigation Measure CC-1 related to compliance with the most 12 State and local plans and regulations addressed in the DTPP Plan-Wide Amendments program SEIR include the following: the CARB 2017 Scoping Plan Update, SB 32, and EO S-3-05; Plan Bay Area 2040; the Redwood City Climate Action Plan (2030); and the CALGreen Code with City of Redwood City Reach Code amendments. ATTY/RESO.0028/CC RESO CEQA GUIDLINES (920 SHASTA) - EXHIBIT A REV: 04-22-25 VR Page 71 of 148