K. Greenhouse Gas Emissions And SustainabilityLSA ASSOCIATES, INC. APPLE CAMPUS 2 PROJECT EIR
JUNE 2015 V. SETTING, IMPACTS AND MITIGATION MEASURES
K. GREENHOUSE GAS EMISSIONS AND SUSTAINABILITY
K. GREENHOUSE GAS EMISSIONS AND SUSTAINABILITY
Increasing public awareness and general scientific consensus that global climate change is occurring
have placed a new focus on CEQA as a potential means to address a project's greenhouse gas (GHG)
emissions. This section begins by providing general background information on climate change and
meteorology. It then provides data on the existing global climate change setting, discusses the
regulatory framework for global climate change, and evaluates potential GHG emissions associated
with the proposed project. Modeled project emissions are estimated based on the land use associated
with the proposed project, project trip generation, energy use, and other variables. The section then
evaluates whether the project could cause a cumulatively considerable contribution to climate change
using methods and assumptions outlined in the Bay Area Air Quality Management District (BAAQMD)
CEQA Air Quality Guidelines.' The information and analysis provided in this section rely primarily on
the Climate Action Team 2006 Final Report, Intergovernmental Panel on Climate Change (IPCC)
Assessment Reports, various California Air Resources Board (ARB) staff reports, and extensive
documentation provided by Apple on the energy-related characteristics of the proposed project.
Closely related to global climate change is the issue of sustainability, which relates to the long-term
use of resources. Sustainable development guidelines have been adopted by cities, counties, and State
agencies throughout California. This section also includes a discussion on concepts of sustainability
and their relation to the proposed project.
1. Global Climate Change Setting
The following discussion provides an overview of global climate change, its causes, its potential
effects, emission sources, and inventories.
a. Global Climate Change Background. A description of global climate change and its sources
is provided below.
(1) Global Climate Change. Global climate change is the observed increase in the average
temperature of the Earth's atmosphere and oceans in recent decades. Global surface temperatures
have risen by 0.74°C ± 0.18°C (1.1 OF ± 0.4°F) between 1906 and 2005. The rate of warming over the
last 50 years of this period is almost double that over the last 100 years .2 The prevailing scientific
opinion on climate change is that most of the warming observed over the last 50 years is attributable
to human activities. The increased amounts of carbon dioxide and other GHGs are the primary causes
of the human -induced component of warming. GHGs are released by the burning of fossil fuels, land
clearing, agriculture, and other activities, and lead to an increase in the greenhouse effect.'
1 Bay Area Air Quality Management District, 2011. CEQA Air Quality Guidelines. May.
2 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 IPCC.
3 The temperature on Earth is regulated by a system commonly known as the "greenhouse effect." Just as the glass in
a greenhouse lets heat from sunlight in and reduces the heat escaping, greenhouse gases like carbon dioxide, methane, and
nitrous oxide in the atmosphere keep the Earth at a relatively even temperature. Without the greenhouse effect, the Earth
would be a frozen globe. Thus, although an excess of GHG results in global warming, the naturally occurring greenhouse
effect is necessary to keep our planet at a comfortable temperature.
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K. GREENHOUSE GAS EMISSIONS AND SUSTAINABILITY
GHGs are present in the atmosphere naturally, are released by natural sources, or are formed from
secondary reactions taking place in the atmosphere. The gases that are widely seen as the principal
contributors to human -induced global climate change are:
• Carbon dioxide (CO2)
• Methane (CH4)
• Nitrous oxide (N20)
• Hydrofluorocarbons (HFCs)
• Perfluorocarbons (PFCs)
• Sulfur hexafluoride (SF6)
Over the last 200 years, humans have caused substantial quantities of GHGs to be released into the
atmosphere. These extra emissions are increasing GHG concentrations in the atmosphere and enhanc-
ing the natural greenhouse effect, which is believed to be causing global warming. While manmade
GHGs include naturally -occurring gases such as CO2, methane, and N20, some gases, like HFCs,
PFCs, and SF6 are completely new to the atmosphere.
Certain gases, such as water vapor, are short-lived in the atmosphere. Others remain in the atmos-
phere for significant periods of time, contributing to climate change in the long term. Water vapor is
excluded from the list of GHGs above because it is short-lived in the atmosphere and its atmospheric
concentrations are largely determined by natural processes, such as oceanic evaporation.
These gases vary considerably in terms of Global Warming Potential (GWP), which is a concept
developed to compare the ability of each GHG to trap heat in the atmosphere relative to another gas.
The GWP is based on several factors, including the relative effectiveness of a gas to absorb infrared
radiation and length of time that the gas remains in the atmosphere ("atmospheric lifetime"). The
GWP of each gas is measured relative to CO2, the most abundant GHG; the definition of GWP for a
particular GHG is the ratio of heat trapped by one unit mass of the GHG to the ratio of heat trapped
by one unit mass of CO2 over a specified time period. GHG emissions are typically measured in terms
of pounds or tons of "CO2 equivalents" (CO2e). Table V.K-1 shows the GWPs for each type of GHG.
For example, SF6 is 22,800 times more potent at contributing to global warming than CO2. The
following discussion summarizes the characteristics of the six GHGs.
Table V.K-1: Global Warming Potential of Greenhouse Gases
Gas
Atmospheric Lifetime
Years
Global Warming Potential
100 -Year Time Horizon
Carbon Dioxide
50-200
1
Methane
12
25
Nitrous Oxide
114
298
HFC -23
270
14,800
HFC -134a
14
1,430
HFC -152a
1.4
124
PFC: Tetrafluoromethane (CF4)
50,000
7,390
PFC: Hexafluoromethane (C2F6)
10,000
12,200
Sulfur Hexafluoride (SF6)
3,200
22,800
Source: IPCC, 2007. Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the
Fourth Assessment Report of the IPCC.
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K. GREENHOUSE GAS EMISSIONS AND SUSTAINABILITY
Carbon Dioxide. In the atmosphere, carbon generally exists in its oxidized form, as CO2.
Natural sources of CO2 include the respiration (breathing) of humans, animals and plants, volcanic
outgassing, decomposition of organic matter, and evaporation from the oceans. Human -caused
sources of CO2 include the combustion of fossil fuels and wood, waste incineration, mineral produc-
tion, and deforestation. Natural sources release approximately 150 billion tons of CO2 each year, far
outweighing the 7 billion tons of man-made emissions of CO2 each year. Natural removal processes,
such as photosynthesis by land- and ocean -dwelling plant species, cannot keep pace with this extra
input of man-made CO2 and consequently the gas is building up in the atmosphere.
Methane. CH4 is produced when organic matter decomposes in environments lacking sufficient
oxygen. Natural sources include wetlands, termites, and oceans. Decomposition occurring in landfills
accounts for the majority of human -generated CH4 emissions in California and in the United States as
a whole. Agricultural processes such as intestinal fermentation, manure management, and rice cultiva-
tion are also significant sources of CH4 in California. CH4 accounted for approximately 6 percent of
gross climate change emissions (CO2e) in California in 2002.
Total annual emissions of CH4 are approximately 500 million tons, with manmade emissions account-
ing for the majority. As with CO2, the major removal process of atmospheric CH4— a chemical break-
down in the atmosphere — cannot keep pace with source emissions, and CH4 concentrations in the
atmosphere are increasing.
Nitrous Oxide. N20 is produced naturally by a wide variety of biological sources, particularly
microbial action in soils and water. Tropical soils and oceans account for the majority of natural
source emissions. N20 is a product of the reaction that occurs between nitrogen and oxygen during
fuel combustion. Both mobile and stationary combustion emit N20, and the quantity emitted varies
according to the type of fuel, technology, and pollution control device used, as well as maintenance
and operating practices. Agricultural soil management and fossil fuel combustion are the primary
sources of human -generated N20 emissions in California. N20 emissions accounted for nearly 7
percent of man-made GHG emissions (CO2e) in California in 2002.
Hydrofluorocarbons, Perfluorocarbons, and Sulfur Hexafluoride. HFCs are primarily used
as substitutes for ozone-depleting substances regulated under the Montreal Protocol .4 PFCs and SF6
are emitted from various industrial processes, including aluminum smelting, semiconductor manufac-
turing, electric power transmission and distribution, and magnesium casting. There is no aluminum or
magnesium production in California; however, the rapid growth in the semiconductor industry leads
to greater use of PFCs. HFCs, PFCs, and SF6 accounted for about 3.5 percent of man-made GHG
emissions (CO2e) in California in 2002.
(2) Impacts of Climate Change. The potential impacts of global climate change are
described in the following section.
4 The Montreal Protocol is an international treaty that became effective on January 1, 1989, and was intended to
protect the ozone layer by phasing out the production of several groups of halogenated hydrocarbons believed to be
responsible for ozone depletion.
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Temperature Increase. State -of -the art climate models indicate that temperatures in California
may be expected to rise 3 O to 10.5OF by the end of the century .s Because GHGs persist for a long
time in the atmosphere, accumulate over time, and are generally well -mixed, their impact on the
atmosphere cannot be tied to a specific point of emission.
Climate change refers to any significant change in measures of climate (such as temperature, precipi-
tation, or wind) lasting for an extended period (decades or longer). Climate change may result from:
• Natural factors, such as changes in the sun's intensity or slow changes in the Earth's orbit
around the sun;
• Natural processes within the climate system (e.g., changes in ocean circulation and
reduction in sunlight from the addition of GHGs and other gases to the atmosphere from
volcanic eruptions); and
• Human activities that change the atmosphere's composition (e.g., through burning fossil
fuels) and the land surface (e.g., from deforestation, reforestation, urbanization, and
desertification).
The primary effect of global climate change has been a rise in the average global temperature. The
impact of human activities on global climate change is readily apparent in the observational record.
For example, surface temperature data show that 11 of the 12 years from 1995 to 2006 rank among
the 12 warmest since 1850, the beginning of the instrumental record for global surface temperature .6
Climate change modeling shows that further warming could occur, which would induce additional
changes in the global climate system during the current century. Changes to the global climate
system, ecosystems, and the environment of California could include, but are not limited to:
• The loss of sea ice and mountain snow pack, resulting in higher sea levels and higher sea
surface evaporation rates with a corresponding increase in tropospheric water vapor due to
the atmosphere's ability to hold more water vapor at higher temperatures;
• Rise in the global average sea level primarily due to thermal expansion and melting of
glaciers and ice caps in the Greenland and Antarctic ice sheets;
• Changes in weather that include widespread changes in precipitation, ocean salinity, and
wind patterns, and more energetic aspects of extreme weather, including droughts, heavy
precipitation, heat waves, extreme cold, and tropical cyclones;
• Decline of the Sierra snowpack, which accounts for a significant amount of the surface
water storage in California, by 70 percent to as much as 90 percent over the next 100 years;
• Increase in the number of days conducive to ozone formation by 25 to 85 percent (depend-
ing on the future temperature scenario) in high -ozone areas of Los Angeles and the San
Joaquin Valley by the end of the 21St century; and
• High potential for erosion of California's coastlines and seawater intrusion into the Delta
and levee systems due to the rise in sea level.
5 California Climate Change Center, 2006. Our Changing Climate. Assessing the Risks to California. July.
6 California, State of, 2009. California Energy Commission's Public Interest Energy Research Program. The Future
is Now: An Update on Climate Change Science, Impacts, and Response Options for California. September.
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Precipitation and Water Supply. Global average precipitation is expected to increase overall
during the 21St century as the result of climate change, but will vary in different parts of the world.
However, global climate models are generally not well suited for predicting regional changes in
precipitation because of the scale of regionally important factors, such as the proximity of mountain
ranges that affect precipitation.'
Most of California's precipitation falls in the northern part of the State during the winter. A vast
network of man-made reservoirs and aqueducts capture and transport water throughout the State from
northern California rivers, as the greatest demand for water comes from users in the southern part of
the State during the spring and summer.' The current distribution system relies on Sierra Nevada
mountain snowpack to supply water during the dry spring and summer months. Rising temperatures,
potentially compounded by decreases in precipitation, could severely reduce spring snowpack,
increasing the risk of summer water shortages. If heat -trapping emissions continue unabated, more
precipitation will fall as rain instead of snow, and the snow that does fall will melt earlier, reducing
the Sierra Nevada spring snowpack by as much as 70 to 90 percent over the next 100 years.
The extent to which various meteorological conditions will affect groundwater supply is unknown.
Warmer temperatures could increase the period when water is on the ground by reducing soil freeze.
However, warmer temperatures could also lead to higher evaporation or shorter rainfall seasons,
shortening the recharge season. Warmer winters could increase the amount of runoff available for
groundwater recharge. However, the additional runoff would occur at a time when some basins,
particularly in Northern California, are being recharged at their maximum capacity.
Where precipitation is projected to increase in California, the increases are focused in Northern
California. However, various California climate models provide mixed results regarding changes in
total annual precipitation in the State through the end of this century; therefore, no conclusion on an
increase or decrease can be made. Considerable uncertainties about the precise effects of climate
change on California hydrology and water resources will remain until there is more precise and
consistent information about how precipitation patterns, timing, and intensity will change.9 The Los
Altos District (LAD) of the California Water Service supplies water to the project site. LAD received
32 percent of its water from wells. The other 68 percent is purchased from the Santa Clara Valley
Water District (SCVWD).10 Local reservoirs, the South Bay Aqueduct, and the San Felipe Central
Valley Project supply water to the SCVWD. In addition, the SCVWD receives water from the San
Francisco Public Utilities Commission (SFPUC)." The Sierra Nevada snowpack, including the Hetch
Hetchy watershed, provides the majority of the SFPUC's total water needs. The SFPUC is a member
of the Water Utilities Climate Alliance, which is a coalition of water utilities that is improving climate
change research and developing strategies for adapting to climate change impacts on water Supply. 12
7 Intergovernmental Panel on Climate Change, 2007, op. cit.
8 California Climate Change Center, 2006, op. cit.
9 California, State of, 2006. Department of Water Resources, Progress on Incorporating Climate Change into
Management of California's Water Resources. July.
10 California Water Service Company, 2011. Los Altos District. 2010 Urban Water Management Plan.
11 Santa Clara Valley Water District, 2011. 2010 Urban Water Management Plan. May
12 San Francisco Public Utilities Commission, 2009. Water Utilities Climate Alliance. Website: www.wucaonline.org .
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Sea Level Rise. Rising sea level is one of the major areas of concern related to global climate
change. Two of the primary causes for a sea level rise are the thermal expansion of ocean waters
(water expanding as it heats up) and the addition of water to ocean basins by the melting of land-
based ice. From 1961 to 2003, the global average sea level rose at an average rate of 0.07 inches per
year, and at an accelerated average rate of about 0.12 inches per year during the last decade of this
period (1993 to 2003).13 Over the past 100 years, sea levels along California's coasts and estuaries
have risen about 7 inches. 14
Sea levels could rise an additional 55 inches by the end of the century as global climate change
continues." Although these projections are on a global scale, the rate of sea level rise along Califor-
nia's coast is relatively consistent with the worldwide average rate observed over the past century.
Therefore, it is reasonable to assume that changes in worldwide sea level rise will also be experienced
along California's coast. 16 Sea level rise of this magnitude would increasingly threaten California's
coastal regions with more intense coastal storms, accelerated coastal erosion, threats to vital levees,
and disruption of inland water systems, wetlands, and natural habitats. Residents may also be affected
if wastewater treatment is compromised by inundation from rising sea levels, given that a number of
treatment plants discharge to the Bay.
Water Quality. Water quality depends on a wide range of variables such as water temperature,
flow, runoff rates and timing, waste discharge loads, and the ability of watersheds to assimilate wastes
and pollutants. Climate change could alter water quality in a variety of ways, including through higher
winter flows that reduce pollutant concentrations (through dilution) or increase erosion of land
surfaces and stream channels, leading to higher sediment, chemical, and nutrient loads in rivers.
Water temperature increases and decreased water flows can result in increasing concentrations of
pollutants and salinity. Increases in water temperature alone can lead to adverse changes in water
quality, even in the absence of changes in precipitation.
Public Health. Global climate change is also anticipated to result in more extreme heat
events .l' These extreme heat events increase the risk of death from dehydration, heart attack, stroke,
and respiratory distress, especially with people who are ill, children, the elderly, and the poor, who
may lack access to air conditioning and medical assistance. According to the California Climate
Change Center, more research is needed to understand the effects of higher temperatures and how
adapting to these temperatures can minimize health effects.18
13 California, State of, 2009. California Energy Commission's Public Interest Energy Research Program. The Future
is Now: An Update on Climate Change Science, Impacts, and Response Options for California. September.
14 Ibid.
15 San Francisco Bay Conservation and Development Commission (BCDC), 2013. San Francisco Bay Scenarios for
Sea Level Rise Index Map http://www.bcdc.ca.gov/planning/climate_change/index map.shtml
16 California, State of, 2006. Department of Water Resources. Progress on Incorporating Climate Change into
Management of California's Water Resources. July.
17 California Climate Change Center, 2006, op. cit.
" Ibid.
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(3) Emissions Inventories. An emissions inventory that identifies and quantifies the primary
human -generated sources and sinks of GHGs is a well-recognized and useful tool for addressing
climate change. This section summarizes the latest information on global, United States, California,
and local GHG emission inventories.
Global Emissions. Worldwide emissions of GHGs in 2004 were 27 billion metric tons of CO2e
per year.19 Global estimates are based on country inventories developed as part of programs of the
United Nations Framework Convention on Climate Change (UNFCCC).
U.S. Emissions. In 2010, the United States emitted about 1,633.2 million metric tons (MMT)
Of CO2e, with each individual at home releasing approximately 4 metric tons per year. Of the four
major sectors nationwide — residential, commercial, industrial and transportation — transportation
accounts for the highest amount of GHG emissions (approximately 35 to 40 percent); these emissions
are entirely generated from direct fossil fuel combustion. Between 1990 and 2009, total U.S. GHG
emissions rose by 7.3 percent, but emissions decreased from 2008 to 2009 by 6.1 percent. This
decrease was primarily due to: (1) a decrease in economic output resulting in a decrease in energy
consumption across all sectors; and (2) a decrease in the carbon intensity of fuels used to generate
electricity due to fuel switching as the price of coal increased, and the price of natural gas dropped
sharply. Since 1990, U.S. emissions have increased at an average annual rate of 0.4 percent .20
State of California Emissions. According to ARB emission inventory estimates, California's
gross emissions of GHGs decreased 1.5 percent, from 463.6 MMT 21 of CO2e emissions in 2000 to
456.8 million in 2009, with a maximum of 488.8 million in 2007.22 During the same period,
California's population grew by 9.1 percent, from 33.9 to 37.2 million people and GHG emissions per
person decreased from 13.7 to 12.4 metric tons of CO2e. The year 2009 saw a 5.8 percent decrease in
Statewide GHG emissions, driven by a noticeable drop in on -road transportation, cement production,
and electricity. The year 2009 also reflects the full effects of the economic recession and higher fuel
prices. As the economy recovers, GHG emissions are likely to rise again without other mitigation
actions.
California has the fourth lowest per -capita CO2 emission rate from fossil fuel combustion in the
country, due to the success of its energy efficiency and renewable energy programs and commitments
19 Combined total of Annex I and Non -Annex I Country CO2e emissions. United Nations Framework Convention on
Climate Change, 2007. GHG Inventory Data. Websites: unfccc.int/glhR data/g_hR data unfccc/time_ series_ annex i/
items/3814.nhn and maindb.unfccc.int/library/view ndf.nl?url=httu://unfccc.int/resource/docs/2005/sbi/ena/18a02.ndf.
20 U.S. Environmental Protection Agency, 2012. The U.S. GHG Emissions and Sinks: Fast Facts. Website:
www.gpa.gov/climatechange/emissions/Usinventolyrgport.html.
21 A metric ton is equivalent to approximately 1.1 tons.
22 California Air Resources Board, 2011. Trends in California GHG Emissions for 2000 to 2009 by Category as
Defined in the Scoping Plan. December. Websites: www.arb.ca.gov/cc/inventoLy/�ubs/rgports/ghg inventory_00-
09 trends.pdf and www.arb.ca.gov/cc/inventory/data/tables/ghg inventory_ trends_ 00-08_2010-05-12.pdf (accessed
November 2011).
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that have lowered the State's GHG emissions rate of growth by more than half of what it would have
been otherwise.23
ARB is responsible for developing the California GHG Emission Inventory. This inventory estimates
the amount of GHGs emitted to and removed from the atmosphere by human activities within the
State and supports the Assembly Bill (AB) 32 Climate Change Program, discussed below. ARB's
current GHG emission inventory for the years 2000 to 2009 (using categories established by ARB) is
shown in Figure V.K-1. The emission inventory estimates are based on the actual amount of all fuels
combusted in the State, which accounts for over 85 percent of the GHG emissions within California.
V.K-1: Ualitornia UHU Emissions by Hector 12000-2UU9 Avera
Inc
Commercial and Residential
9%
High GWP
Note: The High GWP sector encompasses miscellaneous sources.
Transportation
38%
Source: ARB, 2011. Trends in California GHG Emissions for 2000 to 2009 —by Category as Defined in the Scoping Plan.
December. Website: www.arb.ca.gov/cc/inventory/data/tables/ghg inventory scopingplan 00-08 2010-05-
12.1)
Bay Area Emissions Inventory. The BAAQMD has also prepared an inventory of GHG
emissions for the Bay Area. The latest version of the inventory, updated in 2010, provides informa-
tion on 2007 emissions .24 Transportation and industrial/commercial uses are the largest sources of
23 California Energy Commission, 2007. Inventory of California GHG Emissions and Sinks: 1990 to 2004 - Final
Staff Report, publication # CEC-600-2006-013-SF, Sacramento, CA. December 22, 2006; and January 23, 2007 update to
that report.
24 Bay Area Air Quality Management District, 2010. Source Inventory of Bay Area GHG Emissions. Website:
www.baaamd.aov/—/media/Files/Plannine%2Oand%2OResearch/Emission%2Olnventory/reaionalinventorv2007 2 10.ashx.
February
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GHG emissions, each contributing 36.4 percent of the region's total CO2e emissions in the year 2007.
The estimated GHG emissions for the year 2007 for the nine Bay Area counties totaled 95.8 MMT of
CO2e. The Bay Area GHG emissions by sector for the year 2007 are shown in Figure V.K-2.
Figure V.K-2: Bay Area GHG Emissions by Sector (2007)
Source: BAAQNW, 2010. Source Inventory of Bay Area GHG Emissions. February.
b. Regulatory Framework. The regulatory framework and governmental activities addressing
GHG emissions and global climate change are discussed in this section. Although GHG emissions are
being addressed on an international level, federal, State, regional, and local activities are most
applicable to the proposed project and are discussed below.
(1) Federal Regulations. The United States has historically had a voluntary approach to
reducing GHG emissions. However, on April 2, 2007, the United States Supreme Court ruled [549
U.S. 497 (2007)] that the U.S. Environmental Protection Agency (EPA) has the authority to regulate
CO2 emissions under the federal Clean Air Act (CAA). While there currently are no adopted federal
regulations for the control or reduction of GHG emissions, the U.S. EPA commenced several actions
in 2009 to implement a regulatory approach to global climate change, including the ones described
below.
On September 22, 2009, the U.S. EPA issued a final rule for mandatory reporting of GHGs from large
GHG emission sources in the United States. In general, this national reporting requirement will
provide the U.S. EPA with accurate and timely GHG emissions data from facilities that emit 25,000
metric tons or more of CO2 per year. This publicly -available data will allow the reporters to track
their own emissions, compare them to similar facilities, and aid in identifying cost-effective oppor-
tunities to reduce emissions in the future. Reporting is at the facility level, except that certain
suppliers of fossil fuels and industrial GHGs, along with vehicle and engine manufacturers, will
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report at the corporate level. An estimated 85 percent of the total U.S. GHG emissions, from
approximately 10,000 facilities, are covered by this rule.
On December 7, 2009, the U.S. EPA Administrator signed a final action under the CAA, finding that
six GHGs (CO2, CH4, N20, HFCs, PFCs, SF6) constitute a threat to public health and welfare, and
that the combined emissions from motor vehicles contribute to global climate change. This U.S. EPA
action does not impose any requirements on industry or other entities. However, the findings are a
prerequisite to finalizing the GHG emission standards for light-duty vehicles mentioned below. The
U.S. EPA received ten petitions challenging this determination. On July 29, 2010, U.S. EPA denied
these petitions.
On April 1, 2010, the U.S. EPA and the Department of Transportation's National Highway Traffic
Safety Administration (NHTSA) announced a final joint rule to establish a national program consisting
of new standards for model year 2012 through 2016 light-duty vehicles that will reduce GHG emis-
sions and improve fuel economy. U.S. EPA is finalizing the first-ever national GHG emissions
standards under the CAA, and NHTSA is finalizing Corporate Average Fuel Economy standards under
the Energy Policy and Conservation Act. The U.S. EPA GHG standards require light-duty vehicles to
meet an estimated combined average emissions level of 250 grams of CO2 per mile in model year
2016, equivalent to 35.5 miles per gallon.
In December 2010, the U.S. EPA issued its plan for establishing GHG pollution standards under the
CAA in 2011. The agency looked at a number of sectors and is moving forward on GHG standards
for fossil fuel power plants and petroleum refineries — two of the largest industrial sources, represent-
ing nearly 40 percent of the GHG pollution in the United States.zs
On August 9, 2011, U.S. EPA and the NHTSA announced the first-ever standards to reduce GHG
emissions and improve the fuel efficiency of heavy-duty trucks and buses. The final combined
standards of the Heavy -Duty National Program will reduce CO2 emissions by about 270 MMT and
save about 530 million barrels of oil over the life of vehicles built for the 2014 to 2018 model years.
The heavy duty sector addressed in the U.S. EPA and NHTSA rules (including the largest pickup
trucks and vans, semi -trucks, and all types and sizes of work trucks and buses in between) accounts
for nearly 6 percent of all U.S. GHG emissions and 20 percent of transportation emissions. In
addition, air quality will continue to improve as less fuel use leads to reduced ozone and particulate
matter.
(2) State Regulations. The ARB is typically the lead agency for implementing climate
change regulations in the State. There are many regulations and statutes in California that address,
both directly and indirectly, greenhouse gas emissions, such as renewable portfolio standards (SB
1078, SB 107, SB 2(1X)) and energy efficiency standards (Title 24, Cal. Code Regs.). Key State
regulatory activities specifically addressing climate change and greenhouse gas emissions are
discussed below.
25 U.S. EPA, 2010. Press Release. December 23.
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Assembly Bill 1493 (2002). In a response to the transportation sector's significant contribution
to California's CO2 emissions, AB 1493 (Pavley) was enacted on July 22, 2002. AB 1493 requires the
ARB to set GHG emission standards for passenger vehicles and light duty trucks (and other vehicles
whose primary use is noncommercial personal transportation in the State) manufactured in 2009 and
all subsequent model years. These standards (starting in model years 2009 to 2016) were approved by
the ARB in 2004, but the needed waiver of Clean Air Act Preemption was not granted by the U.S.
EPA until June 30, 2009. The ARB responded by amending its original regulation, now referred to as
Low Emission Vehicle III GHG, to take effect for model years starting in 2017 to 202526
Executive Order S-3-05 (2005). Governor Arnold Schwarzenegger signed Executive Order S-
3-05 on June 1, 2005, which proclaimed that California is vulnerable to the impacts of climate
change. To combat those concerns, the executive order established California's GHG emissions
reduction targets, which established the following goals:
• GHG emissions should be reduced to 2000 levels by 2010;
• GHG emissions should be reduced to 1990 levels by 2020; and
• GHG emissions should be reduced to 80 percent below 1990 levels by 2050.
The Secretary of the California Environmental Protection Agency (CalEPA) is required to coordinate
efforts of various State agencies in order to collectively and efficiently reduce GHGs. A biannual
progress report must be submitted to the Governor and State Legislature disclosing the progress made
toward GHG emission reduction targets. In addition, another biannual report must be submitted
illustrating the impacts of global warming on California's water supply, public health, agriculture, the
coastline, and forestry, and report possible mitigation and adaptation plans to address these impacts.
Assembly Bill 32 (2006), California Global Warming Solutions Act. California's major
initiative for reducing GHG emissions is AB 32, passed by the State legislature on August 31, 2006.
This effort aims at reducing GHG emissions to 1990 levels by 2020. The ARB has established the
level of GHG emissions in 1990 at 427 MMT CO2e. The emissions target of 427 MMT requires the
reduction of 169 MMT from the State's projected business -as -usual 2020 emissions of 596 MMT.
AB 32 requires the ARB to prepare a Scoping Plan that outlines the main State strategies for meeting
the 2020 deadline and to reduce GHGs that contribute to global climate change. The Scoping Plan
was approved by the ARB on December 11, 2008, and contains the main strategies California will
implement to achieve the reduction of approximately 169 MMT of CO2e, or approximately 30
percent, from the State's projected 2020 emission level of 596 MMT of CO2e under a business -as -
usual scenario (this is a reduction of 42 MMT CO2e, or almost 10 percent from 2002-2004 average
emissions). The Scoping Plan also includes ARB -recommended GHG reductions for each emissions
sector of the State's GHG inventory. The Scoping Plan calls for the largest reductions in GHG
emissions to be achieved by implementing the following measures and standards:
• Improved emissions standards for light-duty vehicles (estimated reductions of 31.7 MMT
CO2e);
The Low -Carbon Fuel Standard (15.0 MMT CO20;
26 California Air Resources Board, 2010. California Clean Car Standards — Pavely, Assembly Bill 1493. Website:
arb.ca.gov/cc/ccros/ccros.hhn (accessed November 2011).
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• Energy efficiency measures in buildings and appliances and the widespread development of
combined heat and power systems (26.3 MMT COze); and
A renewable portfolio standard for electricity production (21.3 MMT COze).
The Scoping Plan identifies 18 emission reduction measures that address cap -and -trade programs,
vehicle gas standards, energy efficiency, low carbon fuel standards, renewable energy, regional trans-
portation -related GHG targets, vehicle efficiency measures, goods movement, solar roof programs,
industrial emissions, high speed rail, green building strategies, recycling, sustainable forests, water,
and air. The measures would result in a total reduction of 174 MMT COZe by 2020.
On August 24, 2011, the ARB unanimously approved both ARB's new supplemental assessment and
re -approved its Scoping Plan, which provides the overall roadmap and rule measures to carry out AB
32. The ARB also approved a more robust CEQA equivalent document supporting the supplemental
analysis of the cap -and -trade program. ARB also announced that it would be delaying the date that
entities would be required to comply with its cap -and -trade program until 2013.
ARB has not yet determined what amount of GHG reductions it recommends from local government
operations and local land use decisions; however, the Scoping Plan states that land use planning and
urban growth decisions will play an important role in the State's GHG reductions because local
governments have primary authority to plan, zone, approve, and permit how land is developed to
accommodate population growth and the changing needs of their jurisdictions (meanwhile, ARB is
also developing an additional protocol for community emissions). ARB further acknowledges that
decisions on how land is used will have large impacts on the GHG emissions that will result from the
transportation, housing, industry, forestry, water, agriculture, electricity, and natural gas emission
sectors. The Scoping Plan states that the ultimate GHG reduction assignment to local government
operations is to be determined. With regard to land use planning, the Scoping Plan expects an
approximately 5.0 MMT COZe reduction due to implementation of SB 375.
In addition to reducing GHG emissions to 1990 levels by 2020, AB 32 directed the ARB and the
newly created Climate Action Team (CAT) to identify a list of "discrete early action GHG reduction
measures" that could be adopted and made enforceable by January 1, 2010. On January 18, 2007,
Governor Schwarzenegger signed Executive Order S-1-07, further solidifying California's dedication
to reducing GHGs by setting a new Low Carbon Fuel Standard. The Executive Order sets a target to
reduce the carbon intensity of California transportation fuels by at least 10 percent by 2020 and
directs the ARB to consider the Low Carbon Fuel Standard as a discrete early action measure. In
2011, U.S. District Court Judge Lawrence O'Neil issued an injunction preventing implementation of
the Low Carbon Fuel Standard, ruling that it is unconstitutional. In 2012, the Ninth Circuit Court of
Appeal stayed the District Court's injunction, allowing implementation of the Low Carbon Fuel
Standard while the appeal is pending. The Ninth Circuit has not yet issued its decision.
In June 2007, the ARB approved a list of 37 early action measures, including three discrete early
action measures (Low Carbon Fuel Standard, Restrictions on GWP Refrigerants, and Landfill CH4
Capture).27 Discrete early action measures are measures that were required to be adopted as regula-
27 California Air Resources Board, 2007. Expanded List of Early fiction Measures to Reduce Greenhouse Gas
Emissions in California Recommended for Board Consideration. October.
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tions and made effective no later than January 1, 2010, the date established by Health and Safety
Code Section 38560.5. The ARB adopted additional early action measures in October 2007 that
tripled the number of discrete early action measures. These measures relate to truck efficiency, port
electrification, reduction of PFCs from the semiconductor industry, reduction of propellants in
consumer products, proper tire inflation, and SF6 reductions from the non -electricity sector. The
combination of early action measures is estimated to reduce State-wide GHG emissions by nearly 16
MMT.28
Senate Bill 1368 (2006). SB 1368 is the companion bill of AB 32 and was signed by Governor
Schwarzenegger in September 2006. SB 1368 requires the California Public Utilities Commission
(PUC) to establish a GHG emission performance standard for baseload generation from investor-
owned utilities and local publicly -owned utilities These standards cannot exceed the GHG emission
rate from a baseload combined -cycle natural gas fired plant. The legislation further requires that all
electricity provided to California, including imported electricity, must be generated from plants that
meet the standards set by the PUC.
Executive Order S-1-07 (2007). Executive Order S-1-07 indicates that the transportation
sector accounts for over 40 percent of Statewide GHG emissions and establishes a goal to reduce the
carbon intensity of transportation fuels sold in California by a minimum of 10 percent by 2020.
Senate Bill 97 (2007). SB 97, signed by the Governor in August 2007 (Chapter 185, Statutes of
2007; Public Resources Code, Sections 21083.05 and 21097), acknowledges climate change is a
prominent environmental issue that requires analysis under CEQA. This bill directed the OPR to
prepare, develop, and transmit to the California Resources Agency guidelines for mitigating GHG
emissions or the effects of GHG emissions, as required by CEQA.
The California Natural Resources Agency adopted the amendments to the CEQA Guidelines in
January 2010, which went into effect in March 2010. The amendments do not identify a threshold of
significance for GHG emissions, nor do they prescribe assessment methodologies or specific mitiga-
tion measures. The amendments encourage lead agencies to consider many factors in performing a
CEQA analysis, but preserve the discretion granted by CEQA to lead agencies in making their own
determinations based on substantial evidence. The amendments also encourage public agencies to
make use of programmatic mitigation plans and programs when they perform individual project
analyses.
Senate Bill 375 (2008). Signed into law on October 1, 2008, SB 375 supplements GHG reduc-
tions from new vehicle technology and fuel standards with reductions from more efficient land use
patterns and improved transportation. Under the law, the ARB approved GHG reduction targets in
February 2011 for California's 18 federally designated regional planning bodies, known as Metropoli-
tan Planning Organizations (MPOs). The ARB may update the targets every 4 years and must update
them every 8 years. MPOs in turn must demonstrate how their plans, policies and transportation
investments meet the targets set by the ARB through Sustainable Community Strategies (SCS). The
SCS are included with the Regional Transportation Plan (RTP), a report required by State law. How -
28 California Air Resources Board, 2007. "ARB approves tripling of early action measures required under AB 32"
News Release 07-46. Website: www.arb.ca.gov/newsrel/nrl02507.htm. October 25.
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ever, if an MPO finds that their SCS will not meet the GHG reduction target, they may prepare an
Alternative Planning Strategy (APS). The APS identifies the impediments to achieving the targets
Executive Order S-13-08 (2008). Governor Schwarzenegger signed Executive Order S-13-08
on November 14, 2008, which directs California to develop methods for adapting to climate change
through preparation of a Statewide plan. The executive order directed OPR, in cooperation with the
California Resources Agency (CRA), to provide land use planning guidance related to sea level rise
and other climate change impacts by May 30, 2009.
Assembly Bill 900 (2011). Signed into law in 2011, AB 900 allows projects that meet certain
criteria to be designated "Environmental Leadership Development Projects." Projects certified as
such must still undergo the normal review required under CEQA, but in the event of litigation,
covered projects are subject to a streamlined litigation process.29 One of the criteria under AB 900
requires that the ARB must find that the project would "not result in any net additional emissions of
greenhouse gases, including greenhouse gas emissions from employee transportation."
Apple submitted an application under AB 900 to the Governor's Office on April 19, 2012. ARB
conducted its own independent review of the project's greenhouse gas emissions and on June 14,
2012 issued Executive Order LP -12-002 determining that the project would not result in any net
additional greenhouse gas emissions. ARB's analysis was conducted independently from the CEQA
process, using different methodologies. For example, when assessing whether the project meets the
AB 900 standard of producing "no net additional" GHG emissions, the ARB used a different, "Full
Occupancy" baseline than the August 2011 conditions baseline used in this EIR. Apple submitted a
supplement to its application on April 3, 2013. ARB reviewed this supplement and, in a letter dated
April 29, 2013, the Executive Officer confirmed that ARB's determination that the project would not
result in any net additional greenhouse gas emissions remains valid.
(3) Bay Area Air Quality Management District. BAAQMD is the regional government
agency that regulates sources of air pollution within the nine San Francisco Bay Area counties. The
BAAQMD regulates GHG emissions through the following plans, programs, and guidelines.
Clean Air Plans. BAAQMD and other air districts prepare clean air plans in accordance with
the State and federal Clean Air Acts. The Bay Area 2010 Clean Air Plan (CAP) is a comprehensive
plan to improve Bay Area air quality and protect public health through implementation of a control
strategy designed to reduce emissions and ambient concentrations of harmful pollutants. The most
recent CAP also includes measures designed to reduce GHG emissions.
BAAQMD Climate Protection Program. The BAAQMD established a climate protection
program to reduce pollutants that contribute to global climate change and affect air quality in the San
Francisco Bay Area Air Basin. The climate protection program includes measures that promote
29 On April 23, 2012, the Planning and Conservation League (PCL) filed a complaint in Alameda County Superior
Court challenging the constitutionality of parts of California Public Resources Code Section 21185. That section, enacted
under AB 900, requires in part that any challenges to the land use approvals of an AB 900 certified leadership project under
CEQA must be initiated in the California Court of Appeal. On April 9, 2013, the Hon. Frank Roesch, judge of the Alameda
County Superior Court, issued a Statement of Decision determining that the jurisdictional restriction in Public Resources
Code Section 21185(a)(1) is unconstitutional. As of May 23, 2013 that litigation was pending.
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energy efficiency, reduce vehicle miles traveled, and develop alternative sources of energy, all of
which assist in reducing emissions of GHG and in reducing air pollutants that affect the health of
residents. BAAQMD also seeks to support current climate protection programs in the region and to
stimulate additional efforts through public education and outreach, technical assistance to local
governments and other interested parties, and promotion of collaborative efforts among stakeholders.
BAAQMD CEQA Air Quality Guidelines. The BAAQMD CEQA Air Quality Guidelines
were prepared to assist in the evaluation of air quality impacts of projects and plans proposed within
the Bay Area. The guidelines provide recommended procedures for evaluating potential air impacts
during the environmental review process, consistent with CEQA requirements, and include recom-
mended thresholds of significance, mitigation measures, and background air quality information. The
guidelines also include recommended assessment methodologies for air toxics, odors, and greenhouse
gas emissions. In June 2010, the BAAQMD's Board of Directors adopted CEQA thresholds of
significance and an update of the CEQA Guidelines. In May 2011, the updated BAAQMD CEQA Air
Quality Guidelines30 were amended to include a risk and hazards threshold for new receptors and
modified procedures for assessing impacts related to risk and hazard impacts.
On March 5, 2012, the Alameda County Superior Court issued a judgment finding that the BAAQMD
had failed to comply with CEQA when it adopted the thresholds of significance in the BAAQMD
CEQA Air Quality Guidelines. The court did not determine whether the thresholds of significance
were valid on their merits, but found that the adoption of the thresholds was a project under CEQA.
The court issued a writ of mandate ordering the BAAQMD to set aside the thresholds and cease
dissemination of them until the BAAQMD complied with CEQA. In May of 2012, the BAAQMD
filed an appeal of the court's decision, the results of which are pending.
In view of the court's order, the BAAQMD is no longer recommending that the thresholds of
significance from the 2011 CEQA Air Quality Guidelines be used as a generally applicable measure
of a project's significant air quality impacts.31 Following the court order, the BAAQMD released
revised CEQA Air Quality Guidelines in May of 2012 that include guidance on calculating air
pollution emissions, obtaining information regarding the health impacts of air pollutants, and
identifying potential mitigation measures, and which set aside the significance thresholds. The
BAAQMD recognizes that lead agencies may rely on the previously recommended Thresholds of
Significance contained in its CEQA Guidelines adopted in 1999.32 However, the 1999 CEQA
Guidelines do not contain a threshold for greenhouse gas emissions.
Under the 2011 CEQA Air Quality Guidelines, a local government may prepare a qualified GHG
Reduction Strategy that is consistent with AB 32 goals. If a project is consistent with an adopted
qualified GHG Reduction Strategy and General Plan that addresses the project's GHG emissions, it
can be presumed that the project will not have significant GHG emissions under CEQA.33 The 2011
30 Bay Area Air Quality Management District, 2011. CEQA Air Quality Guidelines. May.
31 Bay Area Air Quality Management District, 2013. Website: baagmd.gov/Divisions/Planning-and-
Research/CEQA-Guidelines. aspx
32 Bay Area Air Quality Management District, 1999. BAAQMD CEQA Guidelines, Assessing the Air Quality Impacts
of Projects and Plans. December
33 Bay Area Air Quality Management District, 2011. CEQA Air Quality Guidelines. May.
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Guidelines also included a quantitative threshold for project level analyses based on estimated GHG
emissions as well as per capita metrics.
(4) Metropolitan Transportation Commission/Association of Bay Area Governments
Sustainable Communities Strategy. The Metropolitan Transportation Commission (MTC) is the
federally recognized MPO for the nine county Bay Area, which includes Santa Clara County and the
City of Cupertino. In 2009, MTC adopted its current RTP, Transportation 2035: Change in Motion,
before the ARB adopted GHG reduction targets in 2011. Thus, there is not an applicable SCS for the
City and project. Plan Bay Area is a collaboration between MTC and the Association of Bay Area
Governments (ABAG). In March 2011, Plan Bay Area released its Initial Vision Scenario, which
presents a first draft of targeted growth areas and regional projections. Based on the Initial Vision
Scenario, Plan Bay Area adopted a preferred SCS scenario. On March 22, 2013 the Draft Plan Bay
Area was released and the Plan Bay Area EIR was released on April 2, 2013 for public review and
comment .34 These documents are expected to be certified and adopted in the summer of 2013.
(5) Joint Venture: Silicon Valley. The City of Cupertino is a member of the Joint Venture:
Silicon Valley (JVSV), a not-for-profit corporation whose mission is to bring people together from
business, government, education, and the community to act on regional issues affecting economic
vitality and quality of life. JVSV's covers all of Santa Clara County and portions of San Mateo, Santa
Cruz, and Alameda counties. The organization is governed by a board of business, government,
education, and community leaders .35 In May 2007, JVSV formed a Public Sector Climate Task Force
with the goal of reducing GHG emissions from public agency operations through regional goals and
coordinated emission reduction efforts.
(6) City of Cupertino General Plan. The City of Cupertino addresses global climate change
and GHG emissions through its General Plan, primarily the Environmental Resources/Sustainability
Element.36 The following plan goals, policies and strategies would be expected to reduce GHG
emissions over the long-term in the City.
Policy 5-1: Principles of Sustainability
Incorporate the principles of sustainability into Cupertino's planning and development system.
Strategies
4. Sustainable Energy and Water Conservation Plan. Prepare and implement a comprehensive
sustainability energy plan as a part of the City's General Plan. This plan will specifically include
recommendations regarding:
a. Reduction of energy consumption.
b. Reduction of fossil fuels.
c. Use of renewable energy resources whenever possible.
34 Metropolitan Transportation Commission and the Association of Bay Area Governments, 2013. Website:
onebavarea.org.
35 Joint Venture: Silicon Valley, 1998. The Joint Venture Way: Lessons for Regional Rejuvenation, Vol. 1 & 2.
36 Cupertino, City of, 2005. Cupertino General Plan. November.
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d. Improve City-wide water usage and conservancy.
e. Reduce water consumption by the City.
f Promote residential and business water reduction.
Policy 5-2: Conservation and Efficient Use of Energy Resources
Encourage the maximum feasible conservation and efficient use of electrical power and natural gas resources
for new and existing residences, businesses, industrial and public uses.
Strategies
1. Alternate Energy Sources. Encourage the use of solar energy and other alternate, renewable energy
resources for all new and significantly renovated private and public buildings. Ensure that all homes
have an acceptable balance of access to the sun and protection from it. Promote new technologies,
such as waterless water heaters to effect this change.
2. Comprehensive Energy Management Plan. Prepare and implement a comprehensive energy manage-
ment plan for all applicable public facilities, equipment and procurement and construction practices.
3. Consistency with State and Federal Regulations. Review and evaluate applicable City codes, ordi-
nances, and procedures for inclusion of local, state and federal policies and standards that promote
the conservation and efficient use of energy and for consistency with the goal of sustainability.
Change those that will promote energy efficiency without a punitive effect.
5. Incentive Program. Implement an incentive program to include such items as reduced permit fees for
building projects that exceed Title 24 requirements. Promote other incentives from the State, County
and Federal Governments for improving energy efficiency by posting information regarding
incentive, rebate and tax credit programs on the City's web site.
6. Solar Access Standards. Ensure compliance with the State of California Subdivision Map Act solar
access standards in order to maximize natural heating and cooling opportunities for future
residences. Encourage the inclusion of additional shade trees and landscaping for energy efficiency.
7. Energy Cogeneration Systems. Encourage the use of energy cogeneration systems through the
provision of an awareness program targeting the larger commercial and industrial users and public
facilities.
8. Regulation of Building Design. Ensure designers, developers, applicants and builders meet
California Title 24 Energy Efficient Building Standards and encourage architects, building designers
and contractors to exceed "Title 24" requirements for new projects through the provision of
incentives. Encourage either passive solar heating and/or dark plaster interior with a cover for
swimming pools, cabanas and other related accessory uses where solar access is available.
Encourage the use of alternative renewable sources where feasible, and develop energy audits or
subvention programs.
9. Use of Discretionary Development Permits (Use Permits). Require, as conditions of approval for
new and renovated projects, the provision of energy conservation/efficiency applications.
10. Energy Efficient Transportation Modes. Encourage alternative, energy efficient transportation modes
such as "clean' multi -modal public transit, car and vanpooling, flexible work hours, and pedestrian
and bicycle paths.
Policy 5-3: Green Building Design
Set standards for the design and construction of energy and resource conserving/efficient building (Green
Building Design).
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1. "Green Building" Program. Prepare and implement "Green Building" standards for all major private
and public projects that ensure reduction in energy consumption for new development through site
and building design.
2. Building Energy Audits. Participate in and encourage building energy audits, where feasible, for
commercial, industrial and city facilities and convey to the business and industrial communities that
energy conservation/efficiency is, in the long term, economically beneficial.
Policy 5-6: Walking, Jogging and Bicycling
Encourage walking, jogging and bicycling instead of driving in the City.
Policy 5-28: Interagency Coordination
Actively pursue interagency coordination for regional water supply problem solving.
Policy 5-29: Coordination of Local Conservation Policies with Region -wide Conservation Policies
Coordinate city-wide water conservation efforts with the Santa Clara Valley Water District efforts being
conducted on a regional scale. Many of these conservation efforts are outlined in the Santa Clara Valley Water
District Drought Plan and Countywide Water Use Reduction program.
Policy 5-31: Water Use Efficiency
Promote efficient use of water throughout the City.
Strategies
1. Landscaping Plans. Require water -efficient landscaping plans that incorporate the usage of recycled
water for landscape irrigation as part of the development review process.
Policy 5-38: Commercial/Industrial Recycling
Expand existing commercial and industrial recycling programs to meet and surpass AB 939 waste stream
reduction goals.
Policy 5-40: On-site Garbage Area Dedication
Modify existing, and require for new developments, on-site waste facility requirements for all multi -family
residential, commercial and industrial land uses to have 50 percent of their garbage area dedicated to recycling
and no more than 50 percent garbage.
Policy 5-44: Reuse of Building Materials
Encourage the recycling and reuse of building materials, including recycling materials generated by the
demolition and remodeling of buildings.
Strategies
1. Post Demolition and Remodeling Projects. Encourage contractors to post demolition and remodeling
projects on the Internet announcing the availability of potential reusable materials.
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2. Sustainability Setting
The following discussion summarizes concepts of sustainability from three sources: 1) the City of
Cupertino General Plan (which is also described above); 2) the North Vallco Master Plan; and 3) the
American Planning Association Policy Guide on Planning for Sustainability.
a. City of Cupertino General Plan. The General Plan notes that sustainable planning "integrates
and balances environmental decisions with economic considerations and recognizes the symbiotic
relationship between the natural environment, the community and the economy."37 Sustainability -
related policies from the Environmental Resources/Sustainability Element are listed above, under the
Global Climate Change Setting.
The Environmental Resources/Sustainability Element seeks to incorporate the principles of sustain-
ability into Cupertino's planning and development system, and implementation strategies in the
element are based on the following fundamental principles:
• Linking: the linking of Resource Management and Economic Determinations when
evaluating development projects;
• Conservation/efficiency: the protection, intelligent use and reuse of renewable and
nonrenewable resources;
• Reduction of waste: reuse, recycling and use reduction;
• Resource management: for the benefit of future generations;
• Prevention/mitigation of significant environmental impacts;
• Restoration of impacted environmental resources;
• Innovation in building technologies, including the substitution of materials;
• Community participation: the comprehensive involvement of City government, city
residents and the private sector; and
• Education: preparation and dissemination of educational materials.
b. North Vallco Master Plan. The North Vallco Master Plan contains development guidelines
encompassing an approximately 240 -acre district surrounding the project site (refer to Chapter IV,
Planning Policy, for additional detail). The Master Plan, which has not been adopted by the City
Council and has no legal force or effect, is discussed here for informational purposes. The following
principles of the North Vallco Master Plan are based on sustainability concepts:
• Walkability/Connectivity: Consistent with company security requirements, plan new
development patterns and amenities to facilitate walkability and convenient connections in
the study areas and adjacent areas.
• Sustainability: New development should be encouraged to comprehensively utilize the
knowledge and technology available throughout the planning, design, and construction
process to help achieve sustainability through energy efficiency and resource conservation.
37 Cupertino, City of, 2005. Cupertino General Plan, Environmental Resources/Sustainability Element. November.
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• Efficient Land Utilization: Developable land is a rapidly diminishing resource in Silicon
Valley and new development in the study area should use the land efficiently and wisely.
• Minimization of Traffic Impacts: As change occurs, organize new development to
minimize congestion in this part of the City. Plan short-term development in a forward-
looking matter, e.g., in a way that improves the integration of land use, development form
and transportation infrastructure.
C. American Planning Association Policy Guide on Planning for Sustainability. The Ameri-
can Planning Association (APA) is the primary professional organization for those in the fields of
metropolitan and regional development, community development, urban design, and environmental
planning. The APA has defined sustainability as being "prepared for possible future outcomes; antici-
pating and adapting to change .,38 The APA's Policy Guide on Planning for Sustainability39 is a
comprehensive policy -oriented approach to sustainable development and was adopted by the APA
Board of Directors in 2000. The APA Policy Guide links global un -sustainability indicators (e.g.,
global warming, declining fisheries, soil degradation, species extinction, and economic inequity) and
un -sustainability indicators in the United States (e.g., suburban sprawl, segregation, loss of agricul-
tural land and open space, traffic congestion, and loss of wetlands and degradation of water resources)
to general policy objectives intended to promote sustainability. The intent of the APA Policy Guide is
that the following general objectives be used to create and implement sustainability policies in a
diversity of planning environments:
• Reduce dependence on fossil fuels, extracted underground metals and minerals.
• Reduce dependence on chemicals and other manufactured substances that can accumulate
in nature.
• Reduce dependence on activities that harm life-sustaining ecosystems.
• Meet the hierarchy of present and future human needs fairly and efficiently.
The APA Policy Guide identifies the following specific policy positions:
1. Encourage alternatives to the use of gas -powered vehicles through public transit, alterna-
tively -fueled vehicles, and bicycle and pedestrian -oriented design.
2. Encourage all types of development to use alternative energy sources and meaningful
energy conservation measures.
3. Encourage development, agriculture, and other land uses that minimize the use of extracted
underground minerals.
4. Encourage development and businesses to reduce the use of chemicals and synthetic
compounds.
38 American Planning Association, 2010. Policy Guide on Surface Transportation. Website: www.plaming.org/
policy/guides/adopted/surtacetransportation.htm (accessed April 18, 2012). April.
39 American Planning Association, 2000. Policy Guide on Planning for Sustainability. Website: www.planning.org/
policy/guides/adopted/sustainabilL.htm (accessed April 18, 2012).
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5. Encourage methods of landscape design, landscape and park maintenance, and agriculture
that eliminate use of synthetic fertilizers and pest control and encourage the use of compost
and water conservation.
6. Support compact and mixed-use development that minimizes the need to drive, and the
reclamation of brownfield sites.
7. Conserve undeveloped land, open space, and agricultural land; consciously restore ecosys-
tems and avoid disruptions to natural ecosystems and floodplains.
8. Encourage forms of development, business, and agriculture that reduce the use of water and
employ innovative wastewater treatment.
9. Equitably protect public health, safety, and welfare.
10. Encourage businesses, communities, institutions, and development that pursue reduction
and re -use of by-products and waste.
11. Encourage participatory and partnership approaches to planning that involve the local
community.
12. Support partnerships and initiatives with other organizations that: support development of
technologies that promote sustainability; and provide the best available data for making
informed decisions about development.
13. Support policies, programs, and legislation that improve sustainability.
3. Impacts and Mitigation Measures
This section evaluates significant impacts and appropriate mitigation measures related to GHG
emissions that could result from implementation of the proposed project. The consistency of the
project with general sustainability principles is also discussed.
a. Criteria of Significance. Section 15064.4 of the CEQA Guidelines states that: "A lead agency
should make a good -faith effort, based to the extent possible on scientific and factual data, to
describe, calculate or estimate the amount of greenhouse gas emissions resulting from a project." In
performing that analysis, the lead agency has discretion to determine whether to use a model or
methodology to quantify greenhouse gas emissions, or to rely on a quantitative analysis or perform-
ance-based standards. In making a significance determination, the lead agency then considers the
extent to which the project may increase or reduce greenhouse gas emissions as compared to the
existing environmental setting, whether the project emissions exceed a threshold of significance that
the lead agency determines applies to the project, and the extent to which the project complies with
regulations or requirements adopted to implement a Statewide, regional, or local plan for the
reduction or mitigation of greenhouse gas emissions.
An individual development project typically does not generate a sufficiently large quantity of GHG
emissions to affect global climate change; therefore, the global climate change impacts of the
proposed project are discussed in the context of cumulative impacts, which is the approach in the
BAAQMD Guidelines. This section begins by establishing the thresholds to determine whether an
impact is significant. The latter part of this section identifies GHG emissions associated with existing
operations on the project site and evaluates the GHG emissions expected to result from the project.
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The BAAQMD adopted GHG thresholds of significance in its May 2011 CEQA Air Quality Guide-
lines but has since set them aside in light of a March 2012 Alameda Superior Court order. The
BAAQMD has not adopted thresholds for construction GHG emissions but recommends quantifica-
tion and disclosure of these emissions. Local agencies are encouraged to adopt feasible mitigation
measures to reduce construction emissions. This EIR analyzes whether the project's GHG emissions
would be cumulatively significant.
The BAAQMD's 2011 CEQA Air Quality Guidelines thresholds of significance for operational -
related GHG emissions for land use development projects 40 are:
• Compliance with a qualified GHG Reduction Strategy (an applicable plan, policy or
regulation adopted for the purpose of reducing the emissions of greenhouse gases); or
Annual emissions less than 1,100 metric tons per year of COZe; or
4.6 metric tons COze per service population (residents + employees) per year.
These significance thresholds were adopted as part of the May 2011 CEQA Air Quality Guidelines.
As noted, the BAAQMD has been ordered to set aside the thresholds and is no longer recommending
that they be used as a general measure of a project's significant air quality impacts. The BAAQMD
also recognizes that lead agencies may rely on the previously recommended Thresholds of Signifi-
cance contained in its CEQA Guidelines adopted in 1999.41 However, the 1999 CEQA Guidelines do
not contain a threshold for greenhouse gas emissions.
The court's invalidation of BAAQMD's thresholds presents uncertainty for current project applicants
and local agencies regarding proper evaluation of air quality and GHG emissions in CEQA documents.
Although reliance on the thresholds is no longer required, local agencies still have a duty to evaluate
impacts related to air quality and GHG emissions. In addition, CEQA grants local agencies broad
discretion to develop their own thresholds of significance, or to rely on thresholds previously adopted
or recommended by other public agencies or experts so long as they are supported by substantial
evidence.42 Accordingly, the City of Cupertino has not adopted its own GHG emission thresholds and
is using the BAAQMD's thresholds to evaluate project impacts in order to evaluate the potential
effects of the project on global climate change. The City believes that these protective thresholds are
appropriate in the context of the size, scale, and location of the project. The BAAQMD's approach to
developing a quantitative threshold of significance for GHG emissions was to identify the emissions
level for which a project would not be expected to substantially conflict with existing California
legislation and policy adopted to reduce Statewide GHG emissions. According to the BAAQMD
CEQA Air Quality Guidelines, if a project would generate GHG emissions above the threshold level, it
would be considered to contribute substantially to a cumulative impact, and would be considered
significant. The Alameda County Superior Court did not address the science behind the thresholds or
the merit of the thresholds. Therefore, the City of Cupertino finds that, despite the court ruling, the
40 These include residential, commercial, industrial, and public land uses and facilities.
41 Bay Area Air Quality Management District, 1999. BAAQMD CEQA Guidelines, Assessing the Air Quality Impacts
of Projects and Plans. December.
42 Public Resources Code Section 21082; 14 Cal. Code Regs. Sections 15064.7, 15064.4 (addressing GHG impacts),
see also Citizens for Responsible and Equitable Environmental Development v. City of Chula Vista (2011) 197 Cal.App.4th
327 (upholding city's GHG emissions threshold based on AB 32 compliance).
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science and reasoning contained in the BAAQMD 2011 CEQA Air Quality Guidelines provide the
latest state-of-the-art guidance available. For that reason, substantial evidence supports continued use
of the thresholds in the BAAQMD 2011 CEQA Air Quality Guidelines.
The project would result in significant adverse impacts on global climate change if it would:
• Generate GHG emissions, either directly or indirectly, that may have a significant impact
on the environment, defined as:
Resulting in operational -related GHG emissions that exceed 1,100 metric tons of CO2e
a year, and
Resulting in operational -related GHG emissions that exceed 4.6 metric tons of CO2e
per capita service population (employees) per year; or
• Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing
the emissions of greenhouse gases.
b. Less -Than -Significant Impacts. Implementation of the proposed project would result in less -
than -significant impacts as identified below.
(1) Construction Activities. The project would result in the demolition of all structures
within the project site (consisting of approximately 2,657,000 square feet of building space) and the
ultimate construction of 3,420,000 square feet of office, research, and development uses; 245,000
square feet of auditorium, fitness center, and Valet Parking Reception uses; 92,000 square feet of
utility plants; and parking and ancillary buildings (such as security receptions and landscape in inte-
nance buildings). Of the 3,420,000 square feet of new occupied office and research and development
space, 2,820,000 square feet of building space would be developed as part of Phase 1 and the remain-
ing 600,000 square feet of building space would be constructed at various locations along North
Tantau Avenue at a future date as part of Phase 2.
The project would require approximately 1,690,000 cubic yards of excavation (net) and 1,620,000
cubic yards of fill (net) for Phase 1 and Phase 2 combined .43 Phase 1 would result in a balanced site
and Phase 2 would require approximately 150,000 cubic yards of soil to be exported from the site.
Phase 1 would require approximately 45,000 cubic yards of top soil import and Phase 2 would require
an import of 5,000 cubic yards, for a total top soil import of 50,000 cubic yards. Thus trucks would
export/import a total of 200,000 cubic yards of soil during the duration of the project. Construction
activities, such as site preparation, site grading, on-site heavy-duty construction vehicles, equipment
hauling materials to and from the site, and motor vehicles transporting the construction crew would
produce combustion emissions from various sources.
During construction of the project, GHGs would be emitted through the operation of construction
equipment and from worker and builder supply vendor vehicles, each of which typically uses fossil -
based fuels to operate. The combustion of fossil -based fuels would create GHGs such as CO2, CH4,
and N20. Furthermore, CH4 would be emitted during the fueling of heavy equipment.
43 "Net" indicates the final change in proposed excavation and fill after all excavation and fill has been accounted
for.
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Construction emissions for the proposed project are shown in Table V.K-2. Construction is expected
to occur for a total of 48 months, resulting in total GHG emissions of approximately 47,883 metric
tons of COZe. The BAAQMD does not have an adopted threshold of significance for construction -
related GHG emissions. As shown in Table V.K-2, construction of the project would generate
approximately 17,864 metric tons of COZe in the first year of construction, approximately 15,683
metric tons of COZe in the second year, approximately 13,127 metric tons of COZe in the third year,
with substantially lower emissions in the fourth year of construction. These emissions would be
temporary and limited to the construction period.
Table V.K-2: Project Construction Emissions (Metric Tons)
Year
CO2e
1
17,864
2
15,683
3
13,127
4
1,209
Total
47,883
Source: LSA Associates, Inc. and ENVIRON, 2013.
In connection with the proposed project's designation as an environmental leadership development
project under California Public Resources Code Section 21183, the project applicant agreed to fully
offset the construction emissions of the project by participating in California's Direct Access program
for supplying renewable power and renewable energy credits to certain exiting Apple Cupertino -area
facilities, including the existing campus. However, the construction emissions analysis in this section
does not assume emissions reductions associated with the Direct Access program.
The calculation of construction emissions, as shown in Table V.K-2, incorporates the following
construction protocols that are incorporated as part of the project (see Chapter III, Project
Description) to promote the use of cleaner -burning fuels, increase efficiency, and reduce
construction -related emissions.
To the maximum extent feasible, all construction equipment, diesel trucks, and generators
would be equipped with Best Available Control Technology for emission reductions of
nitrogen oxides and particulate matter.
To the maximum extent feasible, all contractors would use equipment that meets the State
of California Air Resources Board (ARB) most recent certification standard for off-road
heavy duty diesel engines.
Excluding the following equipment, all diesel -powered off-road equipment used on-site
would meet U.S. Environmental Protection Agency (EPA) "Tier 2" exhaust emission
standards, and engines would be equipped with California ARB "Level 3 Verified Diesel
Emission Control Strategies" (which include diesel particulate filters) or would be certified
to meet the U.S. EPA "Tier 4 Interim" standard for particulate matter emissions. Equipment
that would meet U.S. EPA "Tier 2" exhaust emission standards but would not be equipped
with California "Level 3 Verified Diesel Emission Control Strategy" would be limited to:
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C Scrapers 623G
C Scrapers 633B
C Four of the six proposed Scrapers 657G
• Trucks used at the site to haul material and/or soil would be model year 2007 or newer (or
meet equivalent U.S. EPA emission standards).
• Require all aerial and personnel lifts less than 50 horsepower to be fueled with natural gas
or propane.
• Idling time would be minimized by either shutting equipment off when not in use or by
reducing the maximum idling time to 2 minutes. Clear signage would be provided for
construction workers stating these limits at all access points.
• Construction equipment would be maintained and properly tuned in accordance with
manufacturers' specifications.
• When feasible, the project would use locally produced and/or manufactured building
materials for construction of the project.
• A minimum of 75 percent of construction and demolition waste would be diverted from
landfills, to the satisfaction of the City.
• The project would use "Green Building Materials," such as those materials that are
resource efficient, and recycled and manufactured in an environmentally friendly way,
including low volatile organic compound (VOC) materials.
As noted above, the BAAQMD does not have an adopted quantitative threshold for construction
GHG emissions, but recommends the incorporation of construction practices that would reduce
construction emissions. The construction management plan, which is part of the project and would be
enforced through the City's conditions of approval, would ensure that the construction practices listed
above are implemented to reduce construction -related GHG emissions to a less -than -significant level.
(2) Project Operation Impacts. The proposed project would include numerous green
features intended to reduce energy consumption (and associated greenhouse gas emissions). For
purposes of assessing impacts, this analysis evaluates GHG emissions associated with conditions on
the site as of August 2011, at the time the Notice of Preparation was published. Under the August
2011 baseline conditions, approximately 4,844 employees worked on the project site. The current
employee numbers on the site reflect Apple's relocation of its employees in preparation for the
project and Hewlett Packard's consolidation of its employees in Palo Alto. The existing capacity of
the site is approximately 9,800 employees and the site historically has operated closer to full capacity.
However, the conditions of August 2011 function as the baseline for CEQA purposes, and reflect a
cautious approach to evaluating the GHG emissions of the project (one that may over-estimate the
impacts of the proiect).44
44 Because the site would likely return to full utilization without the project, the ARB used a "Full Occupancy
Baseline" in its assessment of whether the project meets the AB 900 standard of producing "no net additional" GHG
emissions.
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Several measures have been incorporated by Apple into the project design that would reduce
emissions in comparison to existing conditions. These measures include:
Site Design
Water
• Services and facilities would be concentrated on one campus, reducing vehicle trips among
dispersed Apple facilities.
• The Central Plant would function as the primary consolidation point for heating, cooling,
and electricity, resulting in economies of scale efficiencies for the Phase 1 development.
• Approximately 10,500 of the 10,980 proposed parking spaces would be provided in sub -
grade levels or within a parking structure, allowing for the provision of additional open
space.
• At least 800 trees would be preserved on the site, at least 90 trees would be transplanted,
and at least 6,200 new trees would be planted.
• Pervious area on the site would be increased from approximately 43 acres to approximately
102 acres.
• Trees would be primarily native and/or drought -resistant species, and trees of diverse ages
would be planted.
• Low -flow fixtures would be incorporated into buildings.
• Recycled water would be used, if available.
• Overall water use would be 30 percent below that of a typical Silicon Valley corporate
campus of similar size.
Energy Efficiency
• Energy-efficient building systems would be incorporated into the design, such as: high -
efficiency radiant conditioning systems; light -emitting diode (LED) electric lighting;
natural ventilation; and user -responsive energy management systems.
• Buildings would be designed for passive heating and cooling.
Renewable Energy Generation
• 100 percent of the project's overall energy needs would be provided by renewable energy,
through the use of photovoltaic systems and fuel cells, and participation in the State of
California Direct Access Program, followed by, if needed, market purchase of renewable
energy credits from new sources that are Green e -certified.
• Photovoltaic cells capable of generating 15,000,000 kilowatt hours/year would be installed
on the roof of the Main Building, the roof of the Main Parking Structure, and as part of
Phase 2 development .41
45 Arup, 2012. MEP — Central Plants, Energy and Equipment Summary.
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Noise
• 300 electrical vehicle charging stations would be provided on-site (with built-in expansion
potential for 1,000 charging stations).
• Mechanical equipment on the project site would be designed such that the operation of such
equipment would not generate noise levels exceeding 65 dBA (daytime) and 55 dBA
(nighttime) at the nearest residential uses. Design features could include barriers and noise
insulation.
Green Building Standards
• The project would exceed the sustainability requirements established by the California
Green Buildings Standard Code (CalGreen, Title 24, Part 11) and the California Energy
Efficiency Standards (Title 24, Chapter 6).
Methodology. The methodology and qualitative description of the sources of GHG emissions
related to transportation, electricity, water use, and solid waste disposal are described below.
Existing Baseline (2011) Emissions. The starting point of the analysis is evaluating and
quantifying existing emissions at the project site, in order to measure whether emissions from the
proposed project would be significant. GHG emissions generated from the existing uses on the project
site were estimated using emission factors from the U.S. EPA and ARB, as well as studies commis-
sioned by California agencies such as the California Energy Commission and CalRecycle. The
analysis calculated emissions from trip estimates from the survey of existing on-site uses. Energy use
data for existing uses on the project site were used to calculate emissions from electricity and natural
gas usage. As shown in Table V.K-3 (below), the total existing operational emissions have been
quantified as 29,513 metric tons per year of CO2e. Additional details on the calculation methods are
provided in Appendix D. These existing annual emissions are then compared to the project's annual
operational emissions in reaching the significance determinations, as discussed further in the
following sections.
Transportation. Transportation associated with the project would result in GHG emissions from
the combustion of fossil fuels in daily automobile and truck trips. Transportation is the largest source
of GHG emissions in California and represents approximately 38 percent of annual CO2 emissions
generated in the State. For land use development projects, vehicle miles traveled (VMT) and vehicle
trips are the most direct indicators of GHG emissions associated with the project. Please refer to
Section V.I, Transportation and Circulation, for a discussion of the project's effects on the transporta-
tion system. The proposed project is forecast to generate 3,274 net new AM peak -hour trips, 3,099 net
new PM peak -hour trips and approximately 35,106 net new daily trips. The proposed project would
provide 300 electric vehicle parking/charging spaces and would install the necessary infrastructure to
allow for up to 1,000 designated electric vehicle parking/charging stations by 2020. The greenhouse
gas emission estimates assume that all 300 parking spaces for electric vehicles would be utilized.
Additionally, as discussed in Section V.I, Transportation and Circulation, Apple provides shuttles to
the campus from various cities throughout the Bay Area. Using actual ridership data in conjunction
with pick-up locations and routes, the greenhouse gas analysis accounts for shuttle vehicle emissions
based on trip length and vehicle type.
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The vacation of Pruneridge Avenue and closure of the street to public travel would divert vehicles
previously traveling through the site to routes around the site on North Tantau Avenue, East Home-
stead Road, and North Wolfe Road. According to traffic modeling conducted by Fehr and Peers, this
re-routing would not cause an overall regional increase in VMT.46
Transportation emissions were calculated using emission factors from the ARB's EMFAC2011 for
the year 2016. In later years, more stringent motor vehicle exhaust emission standards would cause
the operational GHG emissions of the project to decline to below the level of the August 2011
baseline.
Electricity and Natural Gas. Buildings represent approximately 39 percent of primary energy
use and 70 percent of electricity consumption in the U.S. 47 Electricity use can result in GHG produc-
tion if the electricity is generated by combusting fossil fuel. The project's energy requirements would
be met through on-site photovoltaics, fuel cells using natural gas, and participation in California's
Direct Access Program, and, if needed, by market purchase of renewable energy credits from new
sources that are Green -e certified. The project would install approximately 650,000 square feet of
photovoltaics on the roofs of the Main Building and Main Parking Structure.
To offset the emissions of the natural gas needs of the project's gas fired boilers and fuel cells, Apple
has committed to purchasing renewable and biogenic48 directed biogas. Directed biogas could be
delivered to the project site by an off-site renewable biogas producer by means of the existing natural
gas pipeline. As with electricity, there is no means of ensuring the actual molecules of biogas are
consumed at the customer's site. Thus, the gas may not be physically delivered to the site, as the
biogas may actually be utilized at another location along the pipeline route (requiring the use of
natural gas on the project site).
The BAAQMD and ARB do not consider biogenic sources in the quantification of GHG emissions.49
Therefore, all GHG emissions associated with biogenic fuel sources used for the project were not
included in this analysis. All off-site electricity acquired by the project would be obtained via Direct
Access transactions, and would consist of renewable sources, such as wind, solar, and landfill gas -to -
power projects, or renewable energy credits (market purchase of renewable energy credits from new
sources that are certified Green -e Energy providers). All natural gas used at the project site would be
offset by directed biogas. Therefore, the project is not expected to generate any greenhouse gas
emissions associated with electricity or natural gas use.
Water Use. Water- and wastewater -related GHG emissions are based on water supply and
conveyance, water treatment, water distribution, and wastewater treatment. Each element of the water
use cycle has unique energy intensities (in units of kWh per million gallons). Recognizing that the
46 Fehr & Peers Transportation Consultants, 2013. fipple Campus 2 Transportation Impact Analysis.
47 U.S. Department of Energy, 2003. Buildings Energy Data Boob
48 The term biogenic refers to CO2 emissions sources that result from materials that are derived from living cells, as
opposed to CO2 emissions derived from fossil fuels, limestone, and other materials that have been transformed by geological
processes. Biogenic CO2 contains carbon that is present in organic materials that include, but are not limited to, wood, paper,
vegetable oils, animal fat, and food, and animal and yard waste.
49 BAAQMM 2011, op. cit.
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actual energy intensity in each component of the water use cycle will vary by utility, the California
Energy Commission (CEC) assumes that approximately 3,950 kWh per million gallons are consumed
for water that is supplied, treated, consumed, treated again, and disposed of in northern California.
Water use for the proposed project is estimated at 520 acre-feet per year (under the Apple Campus 2
Design Scenario identified in the Water Supply Assessment for the proiect).50 Water usage data from
the 2009 City of Milpitas Water Master Plan (the best available information from a City with similar
commercial land uses) indicates that water usage for similar commercial land uses could be substan-
tially higher. 51 Therefore, to provide the most conservative analysis, a water rate of 774 acre-feet per
year was assumed in this analysis. GHG emissions associated with project water use were estimated
using emission factors from the California Public Utilities Commission (CPUC) and the Water
Energy Team of the Climate Action Team (WetCat).52
Solid Waste Disposal. Solid waste generated by the project could contribute to GHG emissions
in a variety of ways. Average waste generation rates from a variety of sources are available from the
California Integrated Waste Management Board (CIWMB).53 Land filling and other methods of
disposal use energy as part of transporting and managing waste, and these activities produce addi-
tional GHGs to varying degrees. Land filling, the most common waste management practice, results
in the release of CH4 from the anaerobic decomposition of organic materials. CH4 is 25 times more
potent a GHG than CO2. However, landfill CH4 can also be a source of energy. In addition, many
materials in landfills do not decompose fully, and the carbon that remains is sequestered in the landfill
and not released into the atmosphere. Based on data from the City of Los Angeles the average
employee generates 10.53 pounds of solid waste per day. It is estimated that Apple's solid waste
diversion policies result in an 80 percent reduction in waste from average employee waste generation.
However, for purposes of this analysis, it is assumed that a 63 percent reduction would be achieved,
consistent with average waste diversion estimates from CalRecycle. GHG emissions from total
project waste were calculated using methods established by the ARB .54
Project Emissions. When calculating project GHG emissions to compare to the thresholds of
significance, BAAQMD recommends that the lead agency consider project design features, attributes,
and local development requirements as part of the project as proposed and not as mitigation measures.
Therefore, as indicated above, the energy conservation and sustainability measures incorporated into
the project were included in the analysis. Greenhouse gas emissions were estimated using the
methodologies described above.
50 Yarne & Associates, Inc., 2012. SB 610 Water Supply Assessment.
51 Milpitas, City of, 2009. Water Master Plan Update. December. Website: www.ci.milpitas.ca.gov/pdfs/
eng mp water.pdf.
52 California Public Utilities Commission and the Water Energy Team of the Climate Action Team (WetCat), 2010.
Implementing a Public Goods Charge for Water. July. Website: www.wateMlan.water.ca.gov/docs/
cwpu2009/0310final/v4c02al9 cwp2009.pdf.
53 California Department of Resources, Recycling and Recovery, 2010. Estimated Solid Waste Generation Rates for
Commercial Establishments. Website: www.calrec. cl�gov/WasteChar/WasteGen Rates/
Commercial.htm.
54 California Air Resources Board, 2012. Air Resources Board Staff Assessment of the fipple Campus 2 Application
for Environmental Leadership Development Project. June. Website: opr.ca.gov/docs/ARBDetenninationAppleCampus2.pdf.
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Table V.K-3 shows the calculated GHG emissions for existing on-site uses and both phases of the
proposed project. With the project's use of renewable energy, motor vehicle emissions are the largest
source of GHG emissions (approximately 96 percent of the total) associated with the project. Solid
waste and water use are less than 4 percent of the total emissions for the proposed project. Additional
calculation details are provided in Appendix D.
Table V.K-3: GHG Emissions (Metric Tons Per Year)
Emissions Source
Operational Emissions
co, CH4 N,O
COze
Existing Emissions (August 2011 Baseline)
Energy
12,155
— —
12,155
Mobile
16,817
16,817
Water
332
332
Waste
10
209
Total Existing Emissions
29,513
Proposed Project Phase 1 Emissions
Transportation (Vehicles)
29,644
29,644
Transportation (Shuttles)
4,072
4,072
Water
373
373
Solid Waste
—
42 —
890
Total Phase 1 Emissions
34,979
Phase 1 Net New Emissions (over August 2011 Baseline)
5,466
Proposed Project Phase 2 Emissions
Transportation (Vehicles)
2,808
2,808
Transportation (Shuttles)
365
365
Water
25
25
Solid Waste
—
4 —
82
Total Phase 2 Emissions
3,280
Total Project Emissions
38,258
Net New Emissions (over August 2011
Baseline)b
8,745
Note: Column totals may vary slightly due to independent rounding of input data.
Estimates not available for this pollutant and/or category.
a Total project emissions differ from the sum of project Phase 1 and Phase 2 emissions due to rounding.
b Given the ongoing litigation over the Low Carbon Fuel Standard (discussed above), it is possible that the Low Carbon
Fuel standard could be invalidated. This would only change transportation emissions; water and solid waste emissions
are not affected by the Low Carbon Fuel Standard. If the Low Carbon Fuel Standard is not implemented, then the
emission calculations provided above would be altered as follows:
• Phase 1 Emissions (Metric Tons per Year COze): from vehicles: 30,719; from shuttles: 4,220, Total Phase 1
Emissions: 36,201; Net New Emissions: 6,688.
• Phase 2 Emissions (Metric Tons per Year COze): from vehicles: 2,910; from shuttles: 378, Total Phase 2 Emissions
3,395
• Total Project Emissions (Metric Tons per Year COze): 39,596; Net New Emissions 10,083.
Source: LSA Associates, Inc. and ENVIRON, 2013.
Based on the City's significance criteria, a project would have a less -than -significant impact related to
GHG emissions if it would generate less than 1,100 metric tons per year COZe or would result in
emissions per employee of less than 4.6 metric tons per year COZe. Buildout of the project would
result in 9,356 net new employees.
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Model results indicate that Phase 1 and Phase 2 of the project (combined) would generate approxi-
mately 38,258 metric tons per year COZe. As discussed above, existing uses as of August 2011 on the
project site generate 29,513 metric tons per year COZe, which means the proposed project would
generate 8,745 net new metric tons of COZe emissions per year. Taking into account total project
emissions, and dividing these emissions by the total number of project employees (14,200), the
project would result in a per service population emission rate of approximately 2.7 metric tons per
year. While the annual emission rate would exceed the 1,100 metric tons per year threshold, the
annual per capita emissions would be well below the BAAQMD threshold of 4.6 metric tons of COZe
per employee per year, and would therefore not exceed the significance criteria. Greenhouse gas
emissions associated with the project would therefore not make a cumulatively considerable
contribution to a significant impact on the environment.
The significance determination of this analysis is dependent on the project's use of all renewable
energy sources. As part of the AB 900 process, Apple and the City entered into a letter agreement
through which Apple agreed that all measures required for AB 900 certification "shall be conditions
of approval, and those conditions will be fully enforceable by the City of Cupertino." Implementation
of conditions of approval would ensure that all energy used on the site would be derived from
renewable sources, whether generated on-site, purchased via Direct Access transactions with an
Energy Service Provider, or purchased renewable energy credits from new sources that are certified
Green -e Energy providers. Conditions of approval would also require Apple to annually submit
documentation to the City verifying that all energy provided to the site is derived from renewable
sources of electricity such as wind, solar, and landfill gas -to -power projects. In addition, this docu-
mentation would include annual verification that all fuel cell and boiler gas is derived from directed
biogas.
Therefore, with the implementation of the required conditions of approval, the project's GHG emis-
sions would not have a significant impact on the environment.
Project Emissions under Full Occupancy Scenario. This discussion of full occupancy
emissions is provided for informational purposes only. As described in the analysis above, the
determination of significance for the purposes of CEQA utilizes occupancy conditions at the time of
publication of the NOP (August 2011), and atthat time employment on the site (4,844 employees)
was well below the employee capacity of the site (9,800 employees). The site has historically
operated at or near full capacity; however, the August 2011 baseline condition reflects Apple's
relocation of its employees in preparation for the project and Hewlett-Packard's consolidation of its
employees in Palo Alto. According to the Transportation Impact Analysis, new vehicle trips associ-
ated with the project, when compared to traffic conditions under full occupancy of the existing
buildings, would be approximately 16,873 trips — far fewer than the 35,106 net new daily trips
assumed in this EIR analysis under the August 2011 baseline. As shown in Table V.K-3 above, the
primary sources of emissions associated with the project are vehicles. Therefore, the project would
generate substantially fewer emissions when compared to a full occupancy scenario. As part of the
ARB's Executive Order LP -12-002,55 which confirms that the project generates net zero GHG
emissions with respect to AB 900, the ARB calculated GHG emissions under the full occupancy
55 California Air Resources Board, 2012. Exective Order LP -12-002 Relating to Determination of Any NetAddi-
tional Greenhouse Gas Emissions Pursuant to Public Resources Code section 21183, subd. (c). June.
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baseline at 54,482 metric tons per year of COZe. Therefore, buildout of the proposed project would
result in a net reduction of emissions totaling 16,224 metric tons COZe per year, when compared to
the full occupancy scenario.
(3) Compliance with the ARB Statewide GHG Emission Reduction Strategies. The
Cal/EPA CAT and the ARB have developed several reports to achieve the State's GHG targets that
rely on voluntary actions of California businesses, local government and community groups, and
State incentives and regulatory programs. These include the CAT's 2006 "Report to Governor
Schwarzenegger and the Legislature ,"56 ARB's 2007 "Expanded List of Early Action Measures to
Reduce Greenhouse Gas Emissions in California, ,57 and ARB's "Climate Change Scoping Plan: a
Framework for Change."58 These reports identify strategies to reduce California's emissions to the
levels proposed in Executive Order S-3-05 and AB 32. The adopted Scoping Plan includes proposed
GHG reductions from direct regulations, alternative compliance mechanisms, monetary and non -
monetary incentives, voluntary actions, and market-based mechanisms such as cap -and -trade systems.
In addition to reducing GHG emissions to 1990 levels by 2020, AB 32 directed ARB to identify a list
of "discrete early action GHG reduction measures" that can be adopted and made enforceable by
January 1, 2010. In June 2007, ARB approved a list of 37 early action measures, including three
discrete early action measures (Low Carbon Fuel Standard, Restrictions on High Global Warming
Potential Refrigerants,59 and Landfill Methane Capture60). Discrete early action measures are
measures that are required to be adopted as regulations and made effective no later than January 1,
2010, the date established by Health and Safety Code (HSC) Section 38560.5. The ARB adopted
additional early action measures in October 2007 that tripled the number of discrete early action
measures. 61
ARB's focus in identifying the 44 early action items was to recommend measures that ARB staff
concluded were "expected to yield significant GHG emission reductions, [and] are likely to be cost-
effective and technologically feasible." The combination of early action measures is estimated to
reduce Statewide GHG emissions by nearly 16 MMT. Accordingly, the 44 early action items focus on
industrial production processes, and the agriculture and transportation sectors. Early action items
associated with industrial production and agriculture do not apply to the proposed project. The trans-
portation sector early action items such as truck efficiency, low carbon fuel standard, proper tire
inflation, truck stop electrification, and the strengthening of light duty vehicle standards are either not
specifically applicable to the proposed project or would result in a reduction of GHG emissions
associated with the project but are under the control of other regulatory agencies. State measures
include emission reductions assumed as part of the Scoping Plan, including light-duty vehicle GHG
standards (Pavley Standards), the low carbon fuel standard, and energy efficiency measures.
56 California Air Resources Board, 2006. Report to Governor Schwarzenegger and the Legislature.
57 California Air Resources Board, 2007. Expanded List of Early fiction Measures to Reduce Greenhouse Gas
Emissions in California Recommended for Board Consideration. October.
58 California Air Resources Board, 2008. Climate Change Scoping Plan: a fi^amework for change. December.
59 Ibid.
61 Ibid.
61 Ibid.
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Table V.K-4 outlines the project's compliance with the ARB Statewide greenhouse gas emission
reduction strategies.
Table V.K-4: Project Compliance with Greenhouse Gas Emission Reduction Strategies a
Strategy Project Compliance
Ener E tiency Measures
Energy Efficiency
Compliant
Maximize energy efficiency building and appliance stan-
The proposed project would be required to comply with the
dards, and pursue additional efficiency efforts including
updated Title 24 standards for building construction. In
new technologies, and new policy and implementation
addition, the project as designed would utilize all renewable
mechanisms. Pursue comparable investment in energy
sources for its energy needs, which would be enforced via a
efficiency from all retail providers of electricity in
condition of approval and annually verified.
California (including both investor-owned and publicly
owned utilities).
Renewables Portfolio Standard
Achieve a 33 percent renewable energy mix statewide.
Green Building Strategy
Expand the use of green building practices to reduce the
carbon footprint of California's new and existing inventory
of buildings.
Water Conservation and Efficiency Measures
Water Use Efficiency
Compliant
Continue efficiency programs and use cleaner energy
Trees would be primarily native and/or drought -resistant
sources to move and treat water. Approximately 19 percent
species. Low -flow fixtures would be incorporated into
of all electricity, 30 percent of all natural gas, and 88
buildings, and recycled water would be used, if available.
million gallons of diesel are used to convey, treat, distri-
Overall water use is estimated to be 30 percent below that of
bute and use water and wastewater. Increasing the effic-
a typical Silicon Valley corporate campus of similar size.
iency of water transport and reducing water use would
reduce GHG emissions.
Solid Waste Reduction Measures
Increase Waste Diversion, Composting, and
Compliant
Commercial Recycling, and Move Toward Zero -Waste
Apple currently operates a comprehensive integrated recy-
Increase waste diversion from landfills beyond the 50
cling and waste management program including electronic
percent mandate to provide for additional recovery of
waste recycling, recycling of polystyrene, and food compost -
recyclable materials. Composting and commercial
ing. Apple estimates current diversion of waste is approxi -
recycling could have substantial GHG reduction benefits.
mately 80 percent, and has identified a goal to improve that
In the long term, zero -waste policies that would require
rate. In addition, per the City's Construction and Demolition
manufacturers to design products to be fully recyclable
Debris Diversion Ordinance, the construction contractor
may be necessary.
would be required to salvage or recycle at least 60 percent of
the debris from construction to meet City requirements. The
project sponsor would be required to prepare a Waste Man-
agement Plan as a part of the building/demolition permit
application process, and at the completion of project con-
struction, would be required to submit a Construction Recy-
cling Report showing the amount and type of materials
recycled and disposed. The project contractor would develop
a plan to meet or exceed the stated goals for recycling and
salvage. As part of the project, a minimum of 75 percent of
construction and demolition waste would be diverted from
landfills.
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Table V.K-4: Project Compliance with Greenhouse Gas Emission Reduction Strategies a
Strategy Project Compliance
Transportation and Motor Vehicle Measures
Vehicle Climate Change Standards.
Compliant
AB 1493 (Pavley) required the State to develop and adopt
The project does not involve the manufacture, sale, or
regulations that achieve the maximum feasible and cost-
purchase of vehicles. However, vehicles that operate within
effective reduction of GHG emissions from passenger
and access the project site would comply with any vehicle
vehicles and light duty trucks. Regulations were adopted
and fuel standards that the ARB adopts.
by the ARB in September 2004.
Light -Duty Vehicle Efficiency Measures.
Implement additional measures that could reduce light-duty
GHG emissions. For example, measures to ensure that tires
are properly inflated can both reduce GHG emissions and
improve fuel efficiency.
Adopt Heavy- and Medium -Duty Fuel and Engine
Compliant
Efficiency Measures.
Specific regional emission targets for transportation
Regulations to require retrofits to improve the fuel
emissions would not directly apply to the project. However,
efficiency of heavy-duty trucks that could include devices
the project would continue and expand an extensive
that reduce aerodynamic drag and rolling resistance. This
Transportation Demand Management (TDM) Program
measure could also include hybridization of and increased
already in place. The specific measures include a guaranteed
engine efficiency of vehicles.
ride home program (all carpool, vanpool, and transit
participants), shuttle service, carpool incentive program,
Low Carbon Fuel Standard.
bike to work program, flexible work hours, telecommuting
ARB identified this measure as a Discrete Early Action
option, vanpool program, bicycle racks and lockers, and
Measure. This measure would reduce the carbon intensity
other on-site amenities.
of California's transportation fuels by at least 10 percent by
2020. (See previous discussion of the recent Low Carbon
Fuel Standard litigation.)
Regional Transportation -Related Greenhouse Gas
Targets.
Develop regional greenhouse gas emissions reduction
targets for passenger vehicles. Local governments will play
a significant role in the regional planning process to reach
passenger vehicle greenhouse gas emissions reduction
targets. Local governments have the ability to directly
influence both the siting and design of new residential and
commercial developments in a way that reduces green-
house gases associated with vehicle travel.
Measures to Reduce High Global Warming Potential
Compliant
(GWP) Gases.
New products used, sold, or serviced in the project site
ARB has identified Discrete Early Action measures to
would comply with future ARB rules and regulations as
reduce GHG emissions from the refrigerants used in car air
these new rules and regulations are implemented by the
conditioners, semiconductor manufacturing, and consumer
agency.
products. ARB has also identified potential reduction
opportunities for future commercial and industrial
refrigeration, changing the refrigerants used in auto air
conditioning systems, and ensuring that existing car air
conditioning systems do not leak.
a Source of strategies and measures is the California Air Resources Board, Expanded List of Early Action Measures to
Reduce Greenhouse Gas Emissions in California Recommended for Board Consideration. October 2007.
Source: LSA Associates, Inc., 2013.
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The proposed project would not conflict with the AB 32 Scoping Plan, or the early Statewide action
measures in light of the sustainability measures incorporated into the project design that would be
conditions of approval. The proposed project would be compliant with the strategies developed by the
State to reduce GHG emissions; implementation of conditions of approval would ensure this con-
sistency throughout the life of the project. In addition, in developing the thresholds of significance for
GHG emissions, the BAAQMD identified the emissions level for which a project would conflict with
existing California legislation adopted to reduce Statewide GHG emissions. The project would not
exceed the BAAQMD's threshold of significance and therefore, the project would be consistent with
California legislation adopted to reduce GHG emissions.
Consistency with Sustainability Concepts. The purpose of the sustainability analysis is not to
identify additional environmental impacts of the project, but to provide a more complete understand-
ing of the project's environmental implications as they relate to long-term resource use. The analysis
derives from the City's General Plan, North Vallco Master Plan, and the policy positions outlined in
the APA Policy Guide on Planning for Sustainability. In general, the project would substantially meet
accepted sustainability principles.
Alternative Transportation. The project would be generally consistent with this sustainabil-
ity principle. Class II bike lanes (i.e., lanes set aside in streets exclusively for bikes) are
located on all public streets around the project site, including East Homestead Road, North
Tantau Avenue, North Wolfe Road, and Pruneridge Avenue. With the exception of some
portions of Pruneridge Avenue between North Wolfe Road and North Tantau Avenue,
pedestrian access is provided on these streets via sidewalks. Consistent with company
security requirements, private pedestrian and bicycle paths would be developed throughout
the site for Apple employees. Apple would also provide on-site amenities to employees to
reduce mid-day trips.
In addition, Apple would supplement the existing bike paths and sidewalks on North Wolfe
Road, East Homestead Road, North Tantau Avenue, and Vallco Parkway to improve the
bike and pedestrian experience on these streets, since they would serve to replace the
connections lost due to the removal of Pruneridge Avenue. Those improvements would
enhance the bike and pedestrian environment, and provide alternative routes to the segment
of Pruneridge Avenue within the project site.
Apple also offers its employees a comprehensive TDM Program, which is designed to
reduce the use of single -occupancy motor vehicles. As part of the project, Apple would
expand its current TDM program to include a number of new or expanded program
elements, including the following:
Apple Transit. Apple would increase coach service areas and frequency, and provide
priority drop off locations for transit users at its transit center.
o Mass Transit Shuttle Links. Apple shuttle services would be expanded to include
connections to future high-capacity corridors such as VTA BRT lines, electrified
Caltrain lines, and Santa Clara BART extensions.
• Off Campus Bicycle Infrastructure. Off -campus bicycle infrastructure would be improved,
including: bike lanes, bike paths, high -visibility striping, bike boxes at key intersections
and other features to encourage safe cycling to and from the site.
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Campus Walking/Cycling Commutes. Apple would prioritize walking and cycling to the
site for those employees who live closest to the campus by providing more convenient
pedestrian and bicyclist access to the Main Building, providing bike lockers closest to the
entrances of the Main Building, and increasing the distance between on-site parking and
work space (i.e., accommodating much of the project parking underground or in structures,
at a distance from work space).
Transit Center. Apple would provide a transit center with an information desk for
employees to retrieve maps and information on alternative commute options. The
information desk would be easily accessible from the Main Building.
Parking Monitoring System. Apple would develop a parking monitoring system that
would measure individual parking space utilization and collect data to optimize other
TDM programs. For example, arrival time information would help guide new shuttle
schedules throughout the Apple transit system. The system would complement other
TDM programs by identifying open parking spaces in various zones and directing
employees to the closest zone with an open space, which could help reduce on-site
congestion. Some of the data collected would be included in an annual parking
utilization report submitted as part of TDM reporting.
o Expanded Bike -Sharing Program. Apple would provide at least 1,000 bikes within the
project site to enhance mobility and promote cycling as a viable commute option.
o Electric Vehicle Charging. Apple would provide at least 300 charging spaces for
electrical vehicles. While electrical vehicles would not necessarily reduce project
vehicle trips, they would achieve other environmental benefits related to air quality,
noise, and greenhouse gas emissions.
Alternative Energy Sources and Energy Conservation. The project would be consistent
with this sustainability principle. Energy-efficient building systems such as high -efficiency
radiant conditioning systems, LED electric lighting, natural ventilation, and electrical
vehicle charging stations and energy-efficient ICT (Information and Communication
Technology) systems would be incorporated into the design of the project. All of the
project's overall energy needs would be provided by renewable energy, primarily through
photovoltaic systems and fuel cells using directed biogas, supplemented with off-site
renewable energy sources.
Minimize Use of Extracted Underground Minerals and Synthetic Chemicals. The project
would be generally consistent with this sustainability principle. As described above, the
promotion of alternative transportation would reduce the demand for gasoline, which is
derived from extracted underground minerals. In addition, the use of "Green Building
Materials" and the reuse of demolished construction material would also reduce the
demand for mined materials. Because the management plan for open space and landscaped
areas on the project site would be developed when the landscape plan is refined, it is
unknown if the project would use organic methods to maintain open space throughout the
site. However, orchard maintenance on the project site would include organic techniques
and integrated pest management, and trees would be primarily native and/or drought -
resistant species. Fertilizers are made with petroleum inputs and pesticides and herbicides
all rely on synthetic chemicals. Therefore, it is recommended that the project's integrated
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pest management plan include methods of pest prevention that specify the use of pesticides
only as a last resort in pest control.
Reclamation of Brownfield Sites. The project would be consistent with this sustainability
principle. The project site is not subject to large-scale remediation plans. Implementation of
Mitigation Measures 14AZ-1 through HAZ-4, would ensure the safe transport, use, and
handling of hazardous materials during project construction. In addition, the proposed
project would result in redevelopment on already -urbanized land, which, like the reclama-
tion of brownfields, could reduce development pressures on greenfield sites.
Reduce Disruption to Natural Ecosystems. The project would be consistent with this
sustainability principle. With implementation of the project, approximately 102 acres of
land would be landscaped and function as private open space. The increase in open space
that would occur as part of the project would be accomplished primarily through the
provision of a substantial amount of underground and structured parking (approximately
10,500 of the 10,980 spaces), and the consolidation of building space. Of the approximately
4,506 existing trees currently on the project site, at least 887 trees would either be retained
or transplanted, and at least 6,000 trees would be planted on the site. The trees that would
be preserved are primarily located along the periphery of the site and along the Calabazas
Creek riparian corridor. Implementation of Mitigation Measures BIO -1 through BIO -3
would reduce impacts related to bird habitat and bird species, and protected trees on the
project site.
Reduce the Use of Water and Employ Innovative Wastewater Management. The project
would be consistent with this sustainability principle. Stormwater runoff would be
improved on the project site since the project would increase the amount of pervious area
on the site from approximately 43 acres to 102 acres. In addition, trees on the site would be
primarily native and/or drought -resistant species, thus reducing the need for landscape
irrigation on the project site. Other water conservation features include a rainwater capture
system at the Main Building and low -flow fixtures in buildings. Recycled water would also
be used on the site if an extension to a recycled water line is feasible. The overall water use
on the project site would be 30 percent below that of a typical Silicon Valley corporate
campus of similar size.
Reuse of Waste Products. The project would generally be consistent with this sustainability
principle. Apple currently operates a comprehensive integrated recycling and waste
management program including electronic waste recycling, recycling of polystyrene, and
food compositing. Apple estimates current diversion of waste is approximately 80 percent,
and has identified a goal to improve that rate. The project would also be subject to The City
of Cupertino Construction and Demolition Debris Diversion Ordinance ,62 which requires at
least 60 percent of the debris from construction, demolition, and renovation projects to be
diverted from landfills through salvage and recycling practices. As part of the project, a
minimum of 75 percent of construction and demolition waste would be diverted from
landfills.
62 Cupertino, City of, 2010. Municipal Code 16.72.
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C. Significant Impacts. Implementation of the proposed project would not result in any signifi-
cant global climate change impacts.
d. Cumulative Impacts. Cumulative impacts are the collective impacts of one or more past,
present, or future projects, that when combined, result in adverse changes to the environment. Climate
change is a global environmental problem in which: (a) any given development project contributes
only a small portion of any net increase in GHGs and (b) global growth is continuing to contribute
large amounts of GHGs across the world. Land use projects may contribute to the phenomenon of
global climate change in ways that would be experienced worldwide, and with some specific effects
felt in California. However, no scientific study has established a direct causal link between individual
land use project impacts and global warming.
The combination of GHG emissions from past, present, and future projects contributes substantially
to the phenomenon of global climate change and its associated environmental impacts. No individual
project would result in a measurable impact on global climate change. Therefore, this section has
addressed climate change primarily as a cumulative impact. As noted above, in developing the thresh-
old of significance for GHG emissions, the BAAQMD identified the emissions level for which a
project would conflict with existing California legislation adopted to reduce Statewide GHG emis-
sions. According to the BAAQMD, if a project would generate GHG emissions above the threshold
level, it would be considered to contribute substantially to a cumulative impact, and would be
considered significant. As indicated in the analysis presented above, the proposed project, with the
required conditions of approval, would not exceed the project -level significance criteria established
by the BAAQMD and therefore the proposed project would not have a significant cumulative impact
related to GHG emissions and global climate change.
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