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73 a significant VMT impact, the Commercial Component would not result in a new significant impacts or a substantial increase in the severity of previously identified significant impacts related to conflicts with plans, policies, and regulations to reduce greenhouse gas emissions beyond those impacts already identified in the DTPP Plan-Wide Amendments program SEIR and there is no new information of substantial importance for CEQA purposes. In addition, since the 2010 DTPP program EIR, the City of Redwood updated the climate action plan (CAP) (City of Redwood City Climate Action Plan, November 2020). Similar to the previous CAP, the current CAP includes strategies regarding energy and water; transportation and land use; and solid waste. It also includes 33 measures, many of them continued from the previous plan, with new actions related to expansion of energy efficiency and water conservation; incorporation of actions related to energy efficiency, security, and reliability; and community-oriented actions. As with the 2013 CAP, these issues are addressed under specific environmental topics in this Consistency Checklist (e.g., hydrology, transportation, utilities) as standard conditions of approval as part of the City’s ongoing, long-term implementation of its current Climate Action Plan. For all of these reasons, this impact would be less than significant. c. The DTPP program EIR (pp. 13-22 and 13-23) determined that the DTPP area could be subject to flooding due to sea level rise associated with global climate change, placing people, structures, and other improvements at an increased risk of injury or loss from flooding. DTPP program EIR Mitigation Measure 13-1 required that the City prepare strategies to respond to the impact of flooding, but acknowledged that given the unprecedented nature and uncertainty regarding this emerging issue, it could not be concluded that Mitigation Measure 13-1 would reduce this potential impact to a less-than-significant level. The City Council of Redwood City concluded that the environmental, social, economic, and other benefits of the DTPP override the significant adverse impacts of flooding due to sea level rise and adopted a Statement of Overriding Considerations to that effect. The DTPP program EIR determined that no additional sea level rise impacts beyond those identified and analyzed in the DTPP program EIR are anticipated. The DTPP Plan-Wide Amendments program SEIR (pp. 13-49 through 13-50) generally concurred with the DTPP conclusion with respect to potential flooding due to sea level rise. However, the DTPP Plan-Wide Amendments program SEIR explained that due to the 2015 California Supreme Court ruling regarding strict limits on CEQA review of the impacts of the environment on a project, as opposed to the impacts of a project on the environment (see California Building Industry Association v. Bay Area Air Quality Management District [2015] 62 Cal.4th 369), the DTPP Plan-Wide Amendments program SEIR would only provide analysis with respect to the potential for future development under the proposed DTPP Plan-Wide Amendments to exacerbate the effects of sea level rise. The DTPP Plan-Wide Amendments program SEIR (p. 13-50) concluded that the proposed DTPP Plan-Wide Amendments, with implementation of SEIR Mitigation Measure CC-1, which would enforce a no natural gas requirement and require compliance with EV requirements in CALGreen Tier 2, would “result in an increase in GHG emissions that is not cumulatively considerable, and thus would not exacerbate sea level rise,” and would result in a less-than-significant impact related to exposure of people or structures to a significant risk of loss, injury or death involving flooding caused by sea level rise from global climate change, and no mitigation would be required. Through implementation of its Climate Action Plan (adopted in April 2013 and updated in 2020) and General Plan policies – especially in the Built Environment, Public Safety, and Natural Resources chapters – the City continues to develop and implement strategies and programs for addressing anticipated sea level rise. As discussed in item (b), the current CAP includes strategies regarding energy and water; transportation and land use; and solid waste. It also includes 33 measures related to expansion of energy efficiency and water conservation; incorporation of actions related to energy efficiency, security, and reliability; and community-oriented actions. These issues are addressed under specific environmental topics in this Consistency Checklist (e.g., hydrology, transportation, utilities) as standard conditions of approval as part of the City’s ongoing, long-term implementation of its current Climate Action Plan. In addition, Redwood City plans to coordinate closely with the County of San Mateo on adaptation planning efforts through the County’s multi-sector adaptation strategy, Climate Ready SMC. Because the proposed Commercial Component is in compliance with all applicable DTPP regulations and is consistent with City plans and regulations pertaining to climate change, no new or increased sea level rise impacts beyond those identified and analyzed in the DTPP program EIR and DTPP Plan-Wide Amendments program SEIR are anticipated and there is no new information of substantial importance for CEQA purposes. Also see item X, Hydrology, of this Checklist, for a discussion of flooding. CONCLUSION With regards to the issue area of Greenhouse Gas Emissions, the following findings can be made: (1) no peculiar impacts to the Commercial Component or its site have been identified, (2) there are no potentially significant effects or off-site and/or cumulative impacts which were not discussed by the EIR/SEIR, (3) no substantial new information ATTY/RESO.0028/CC RESO CEQA GUIDLINES (920 SHASTA) - EXHIBIT A REV: 04-22-25 VR Page 73 of 148