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5.21 Climate Change

specifications that contractors set goals to limit unnecessary construction
equipment idling to three minutes and provide a program to encourage
equipment operators to achieve the three-minute goal. This requirement
exceeds State regulations (California Code of Regulations [CCR], Title 13,
2449[d][2]) that limit idling to five minutes.

5.21.5 THRESHOLD CRITERIA

CEQA Thresholds

The following significance threshold criteria are derived from the County of Los Angeles
Environmental Checklist and track the thresholds recommended in the State CEQA
Guidelines as amended by the California Natural Resources Agency (CNRA) (CNRA 2009a).
The Project would result in a significant impact if it would:

Threshold 21-1 Generate greenhouse gas emissions, either directly or indirectly, that
may have a significant impact on the environment.

Threshold 21-2 Conflict with an applicable plan, policy or regulation adopted for the
purpose of reducing the emissions of greenhouse gases.

Neither the County’s Environmental Checklist nor the State CEQA Guidelines prescribe
specific methodologies and significance criteria for determining the significance of GHG
emissions impacts. The State CEQA Guidelines emphasize the lead agency's discretion to
determine the appropriate thresholds consistent with the manner in which other impact
areas are handled in CEQA. CEQA cases have upheld local agencies discretion to determine
the significance of GHG emissions.

As with all determinations made in preparing an EIR, pursuant to Section 15064.7(b) of the
State CEQA Guidelines, even without the express discretion as is the case for GHG, the
substantial evidence standard applies to an agency's determination of the significance of an
impact. Under Section 15384, substantial evidence is defined as “facts, reasonable
assumptions predicated upon facts, and expert opinion supported by facts”. Under the
substantial evidence standard, even if there is other information that supports a contrary
conclusion, or a disagreement among experts as to the methodology or significance criteria,
so long as the agency decision is supported by substantial evidence, it will be upheld even if
there is other substantial evidence or expert opinions to the contrary (California 1988, p.
407). As such, an agency determination of significance is upheld so long as it is based on
substantial evidence.

Determining how to analyze the significance of a project's climate change impacts poses a
difficulty for lead agencies. The science in this area is evolving constantly. At the same time,
local agencies do not specialize in this area, and there are currently no local, regional, or
statewide significance criteria for determining whether a mixed-use residential
development in the County of Los Angeles has a “significant” impact on climate change.
Although the CNRA has adopted the CEQA Amendments developed by OPR pursuant to SB
97, as discussed above, the CEQA Amendments pose two questions that agencies should

R:\Projects\PAS\CEN\000306\Draft EIR\5.21 ClimateChange-051117.docx 5.21-46 Centennial Project
Draft EIR