Attachment 10 - Playbook Responses and Final IS-ND — Sunnyvale City Council, June 25, 2024 (part 2 of 2)

Environmental Checklist
Mineral Resources

Final Initial Study–Negative Declaration 75
12 Mineral Resources

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Result in the loss of availability of a known
mineral resource that would be of value to
the region and the residents of the state? □ □ □ ■
b. Result in the loss of availability of a locally
important mineral resource recovery site
delineated on a local general plan, specific
plan, or other land use plan? □ □ □ ■
a. Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
b. Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? According to the Sunnyvale General Plan Land Use and Transportation Element, there are no active mines and no known areas with mineral resource deposits in Sunnyvale, and no minerals or aggregate resources of Statewide importance are located in Sunnyvale.86 Furthermore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would not facilitate projects within the City that could result in the loss of availability of known mineral resources. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to mineral resources.

86 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed December 2023).

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City of Sunnyvale
Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

76 13 Noise

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project result in:
a. Generation of a substantial temporary or
permanent increase in ambient noise levels
in the vicinity of the project in excess of
standards established in the local general
plan or noise ordinance, or applicable
standards of other agencies? □ □ ■ □
b. Generation of excessive groundborne
vibration or groundborne noise levels? □ □ ■ □
c. For a project located within the vicinity of a
private airstrip or an airport land use plan
or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project expose people residing or working
in the project area to excessive noise
levels? □ □ □ ■
a. Would the project result in exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Noise is unwanted sound that disturbs human activity. Environmental noise levels typically fluctuate over time, and different types of noise descriptors are used to account for this variability. Noise level measurements include intensity, frequency, and duration, as well as time of occurrence. Noise level (or volume) is generally measured in decibels (dB) using the A-weighted sound pressure level (dBA). Because of the way the human ear works, a sound must be about 10 dBA greater than the reference sound to be judged as twice as loud. In general, a 3 dBA change in community noise levels is noticeable, while 1-2 dBA changes generally are not perceived. Quiet suburban areas typically have noise levels in the range of 40-50 dBA, while arterial streets are in the 50-60+ dBA range.

Normal conversational levels are in the 60-65 dBA range, and ambient noise levels greater than 65 dBA can interrupt conversations.

Noise levels typically attenuate (or drop off) at a rate of 6 dBA per doubling of distance from point sources (such as construction equipment). Noise from lightly traveled roads typically attenuates at a rate of about 4.5 dBA per doubling of distance. Noise from heavily traveled roads typically attenuates at about 3 dBA per doubling of distance, while noise from a point source typically attenuates at about 6 dBA per doubling of distance. Noise levels may also be reduced by the introduction of intervening structures. For example, a single row of buildings between the receptor Attachment 10

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Environmental Checklist
Noise

Final Initial Study–Negative Declaration 77
and the noise source reduces the noise level by about 5 dBA, while a solid wall or berm that breaks the line-of-sight reduces noise levels by 5 to 10 dBA.

The Sunnyvale General Plan Safety and Noise Element identifies roadway vehicles as Sunnyvale’s main source of noise, followed by Moffett Federal Airfield, the Caltrain corridor, and San Jose International Airport. The Sunnyvale General Plan Safety and Noise Element and SMC Section

19.42.030 aim to ensure appropriate noise levels considered compatible for community noise environments.87, 88 The City’s normally acceptable exterior noise exposure standards are shown in Table 6.

Table 6 Exterior Noise Compatibility Standards
Land Use Type
Highest Level of Exterior Noise
Exposure that is Regarded as
“Normally Acceptable” (Ldn)
Residential: Low- Density Detached Single-Family Homes, Duplexes, Mobile Homes
60 dBA
Other Residential: Townhomes, Multi-Family Apartments, Condominiums, and all other residential
65 dBA
Lodging: Motels and Hotels 70 dBA
Outdoor Activities: Golf Courses, Cemeteries, Parks 75 dBA Schools, Libraries, Museums, Hospitals, Personal Care, Meeting Halls, Churches
70 dBA
Office Buildings, Commercial and Professional Businesses 70 dBA Auditoriums, Concert Halls, Amphitheaters, Sports Arena, Outdoor Spectator Sports
70 dBA
Industrial, Manufacturing, Utilities 75 dBA
Source: Sunnyvale General Plan Safety and Noise Element, Figure 6-6 Construction noise is regulated by SMC Section 16.08.030, which provides an exemption to the noise regulations for construction occurring between the hours of 7:00 am and 6:00 pm on weekdays and 8:00 am and 5:00 pm on Saturdays. Construction is prohibited on Sundays.89 No loud environmentally disruptive noises, such as air compressors without mufflers, continuously running motors or generators, loud playing musical instruments, radios, etc., is allowed where such noises may be a nuisance to adjacent residential neighborhoods. SMC Section 19.42.030 regulates operational noise within residential and nonresidential areas of the City and provides special exceptions to the noise limits for powered equipment, leaf blowers, deliveries, warning sounds, and other activities.90

87 Sunnyvale, City of. 2011. General Plan Safety and Noise Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/602/638370338402370000 (accessed February 2024). 88 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Section 19.42.030, Noise or sound level. https://ecode360.com/42730950?highlight=&searchId=16742807840881719#42730950 (accessed February 2024). 89 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Section 16.08.030, Hours of construction—Time and noise limitations. https://ecode360.com/42720748?highlight=&searchId=16742406866224120#42720748 (accessed February 2024). 90 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Section 19.42.030, Noise or sound level. https://ecode360.com/42730950?highlight=&searchId=16742807840881719#42730950 (accessed February 2024).

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City of Sunnyvale
Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

78 The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to excessive noise levels. The Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing programs that are consistent with the General Plan. Some of the Sunnyvale Playbook Update/Game Plan 2028 Plays would support small-scale construction projects that could result in temporary noise. Sunnyvale Playbook Update/Game Plan 2028 Plays 1.2 and 1.3 would result in the addition of solar PV and thermal energy systems, along with battery storage, within the City. Play 2.2 promotes electrification of existing residential, commercial, and municipal buildings, which may require minor construction to modify the electrical and natural gas connections to existing buildings. Play 3.2 would encourage development of new bicycle and pedestrian infrastructure, which may involve construction activities to create new bike lanes and bike/pedestrian paths throughout Sunnyvale.

Play 3.3 would incentivize or require the installation of new EV charging stations. In addition, Play

4.3 seeks to increase the number of trees throughout Sunnyvale, which may require the use of construction equipment for the moving and placement of trees. However, future Sunnyvale Playbook Update/Game Plan 2028-related projects would be reviewed for consistency with the Sunnyvale General Plan and SMC, and construction activities would be required to comply with the provisions of SMC Section 16.08.030, including the permitted construction hours. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 would not result in significant construction noise impacts.

The Sunnyvale Playbook Update/Game Plan 2028 does not include future projects that would result in substantial operational noise. Rather, the Sunnyvale Playbook Update/Game Plan 2028 encompasses a suite of GHG-reduction opportunities, including those that affect the transportation sector and its associated noise. For example, Sunnyvale Playbook Update/Game Plan 2028 Plays 3.3 and 3.4 encourage adoption of EVs and electric small engine and off-road equipment that are quieter than gas-powered alternatives. In addition, Plays 3.1 and 3.2 seek to reduce VMT in the City and facilitate improvements to bicycle, pedestrian, and public transit circulation to increase active transportation and transit ridership. These Plays would reduce roadway vehicle-related noise in Sunnyvale that is the major source of noise pollution identified in the General Plan Safety and Noise Element.91 Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would not generate excessive noise levels and would result in a less-than-significant impact related to noise exposure.
b. Would the project result in exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels?
While people have varying sensitivities to vibrations at different frequencies, in general they are most sensitive to low-frequency vibration. Vibration in buildings, such as from nearby construction activities, may cause windows, items on shelves, and pictures on walls to rattle. Vibration of building components can also take the form of an audible low-frequency rumbling noise, referred to as groundborne noise.92 Although groundborne vibration is sometimes noticeable in outdoor environments, it is almost never annoying to people who are outdoors. The primary concern from

91 Sunnyvale, City of. 2011. General Plan Safety and Noise Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/602/638370338402370000 (accessed February 2024). 92 Caltrans. 2020. Transportation and Construction Vibration Guidance Manual (CT-HWANP-RT-13-069.25.3). https://dot.ca.gov/- /media/dot-media/programs/environmental-analysis/documents/env/tcvgm-apr2020-a11y.pdf (accessed February 2024).

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Environmental Checklist
Noise

Final Initial Study–Negative Declaration 79
vibration is that it can be intrusive and annoying to building occupants and vibration-sensitive land uses.

Vibration amplitudes are usually expressed in peak particle velocity (PPV) or Root Mean Square (RMS) vibration velocity. The PPV and RMS velocity are normally described in inches per second (in/sec). PPV is defined as the maximum instantaneous positive or negative peak of a vibration signal. PPV is often used in monitoring of blasting vibration because it is related to the stresses that are experienced by buildings.93 Vibration significance ranges from approximately 50 vibration decibels (VdB), which is the typical background vibration-velocity level, to 100 VdB, the general threshold where minor damage can occur in fragile buildings. The general human response to different levels of groundborne vibration velocity levels is described in Table 7.

Table 7 Human Response to Different Levels of Groundborne Vibration94 Vibration Velocity Level Human Reaction
65 VdB Approximate threshold of perception for many people 75 VdB Approximate dividing line between barely perceptible and distinctly perceptible. Many people find that transportation-related vibration at this level is unacceptable. 85 VdB Vibration acceptable only if there are an infrequent number of events per day VdB = vibration decibels
Source: Federal Transit Administration Transit Noise and Vibration Impact Assessment Manual The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to groundborne vibration. The Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing programs that are consistent with the Sunnyvale General Plan. Some of the proposed Sunnyvale Playbook Update/Game Plan 2028 Plays would support small-scale construction projects, such as EV charging station construction and new bicycle lanes, that may result in a temporary, minor increase in groundborne vibration during construction. However, Sunnyvale Playbook Update/Game Plan 2028 projects would be subject to review by the City for compliance and consistency with SMC Section

19.42.060, which regulates vibration in the City, and construction activities would be required to comply with applicable local, State, and federal regulations to minimize temporary construction impacts related to groundborne vibration.95 Furthermore, Sunnyvale Playbook Update/Game Plan 2028 projects would not include operational sources of groundborne vibration. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to groundborne vibration. c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?

93 Federal Highway Administration (FHWA). 2006. FHWA Highway Construction Noise Handbook. (FHWAHEP-06-015; DOT-VNTSC-FHWA- 06-02). https://www.fhwa.dot.gov/Environment/noise/construction_noise/handbook/handbook00.cfm (accessed February 2024). 94 Federal Transit Administration. 2018. Transit Noise and Vibration Impact Assessment Manual. https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessment- manual-fta-report-no-0123_0.pdf (accessed February 2024). 95 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Section 19.42.060, Ground vibration regulated. https://ecode360.com/42730957?highlight=&searchId=16744449726465578#42730957 (accessed February 2024).

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City of Sunnyvale
Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

80 Sunnyvale does not contain any airports but is located adjacent to the Moffett Federal Airfield. The Santa Clara County Airport Land Use Commission (ALUC) has advisory powers over new land uses in the vicinity of airports and establishes 65 dBA CNEL as the maximum allowable noise level considered compatible with residential uses. The unacceptable noise areas resulting from Moffett Federal Airfield are contained within the airport.96 The CEQA GHG Emissions Thresholds and Sunnyvale Playbook Update/Game Plan 2028 are policy documents that would not increase airport activity or result in additional habitable development or commercial development that could increase potential exposure of residents and employees to aircraft-related noise from Moffett Federal Airfield. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to aviation-related noise exposure.

As a guidance document, the CEQA GHG Emissions Thresholds would not result in any development or land use changes that could result in cumulative impacts related to noise. However, future Sunnyvale Playbook Update/Game Plan 2028-related projects, in combination with other cumulative projects that occur to accommodate Sunnyvale’s anticipated population, housing, and employment growth, would support construction projects, such as EV charging station construction, that may result in a temporary increase in groundborne vibration or noise levels. However, cumulative projects, including Sunnyvale Playbook Update/Game Plan 2028 projects, would be subject to review by the City for compliance with the Sunnyvale General Plan and SMC and would be required to comply with applicable local, State, and federal regulations governing construction noise and vibration. Additionally, the Sunnyvale Playbook Update/Game Plan 2028 encompasses a suite of GHG-reduction opportunities that would decrease VMT and roadway vehicle-related noise. As such, implementation of the Sunnyvale Playbook Update/Game Plan 2028 would not generate permanent, excessive groundborne vibration or noise levels. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in an overall less-than- significant cumulative impact related to noise.

96 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed February 2024).

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Environmental Checklist
Population and Housing

Final Initial Study–Negative Declaration 81
14 Population and Housing

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Induce substantial unplanned population
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example,
through extension of roads or other
infrastructure)? □ □ □ ■
b. Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere? □ □ □ ■
a. Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
b. Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
The Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds are policy documents and do not propose development or changes to land use and zoning designations. Thus, implementation of the Sunnyvale Playbook Update/Game Plan 2028 would not result in construction or operational impacts related to substantial unplanned population growth or the displacement of existing people or housing. In addition, the Sunnyvale Playbook Update/Game Plan 2028 does not propose new roadways or utilities that could indirectly lead to new population growth or development. As such, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would not directly increase the population, indirectly induce additional unplanned population growth, or displace people or housing. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to population and housing.

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City of Sunnyvale
Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

82 population growth within the City. Specifically, the Sunnyvale Playbook Update/Game Plan 2028 would not contribute to person or housing displacement in Sunnyvale nor result in population growth beyond that already assumed and planned for in the Sunnyvale General Plan and in accordance with Sunnyvale 2040 population projections. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no cumulative impact related to population and housing.

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Environmental Checklist
Public Services

Final Initial Study–Negative Declaration 83
15 Public Services

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
a. Would the project result in substantial
adverse physical impacts associated with
the provision of new or physically altered
governmental facilities, or the need for
new or physically altered governmental
facilities, the construction of which could
cause significant environmental impacts, in
order to maintain acceptable service ratios,
response times or other performance
objectives for any of the public services:

1. Fire protection? □ □ □ ■

2. Police protection? □ □ □ ■

3. Schools? □ □ □ ■

4. Parks? □ □ □ ■

5. Other public facilities? □ □ □ ■
a. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
▪ Fire protection?
▪ Police protection?
▪ Schools?
▪ Parks?
▪ Other public facilities?
The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to public services.

Likewise, the Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing programs that are consistent with the Sunnyvale General Plan and does not propose specific development or changes to land use and zoning designations. Implementation of the Sunnyvale Playbook Update/Game Plan 2028 and its proposed Plays and Moves would not result in increases in population or new employment opportunities that could induce population growth, as further Attachment 10

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City of Sunnyvale
Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

84 discussed in Section 14, Population and Housing. As such, the Sunnyvale Playbook Update/Game Plan 2028 would not require the construction of new or physically altered governmental (i.e., fire protection, police protection, schools, parks, libraries) facilities to serve additional population, the construction of which could cause significant environmental impacts. Sunnyvale Playbook Update/Game Plan 2028 Plays 6.1 through 6.3 would help to increase community resiliency, reduce vulnerability to the impacts of climate change, and mitigate hazards such as flooding within Sunnyvale, thereby reducing the burden on local public services related to such natural disasters.

Furthermore, future Sunnyvale Playbook Update/Game Plan 2028 projects and actions would be reviewed for consistency with the Sunnyvale General Plan and other applicable local and State regulations related to public services. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to public services in terms of need for the construction of new or altered governmental facilities.

Cumulative Impacts
The cumulative projects scenario is the population, employment, and households forecasts identified in the supporting documentation for the Sunnyvale Playbook Update/Game Plan 2028, based on demographic data contained in Plan Bay Area 2040 (refer to Table 5). As a guidance document, the CEQA GHG Emissions Thresholds would not result in cumulative impacts related to public services and facilities. Likewise, implementation of future Sunnyvale Playbook Update/Game Plan 2028 projects, in combination with other cumulative development that occurs to accommodate Sunnyvale’s anticipated population, employment, and housing growth, would not result in increases in population or induce additional population growth beyond that assumed under the Sunnyvale General Plan and 2040 population projections. As such, implementation of the Sunnyvale Playbook Update/Game Plan 2028 would not result in cumulative need to construct or expand public services facilities. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no cumulative impact related to public services.

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Environmental Checklist
Recreation

Final Initial Study–Negative Declaration 85
16 Recreation

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Increase the use of existing neighborhood
and regional parks or other recreational
facilities such that substantial physical
deterioration of the facility would occur or
be accelerated? □ □ □ ■
b. Include recreational facilities or require the
construction or expansion of recreational
facilities which might have an adverse
physical effect on the environment? □ □ □ ■
a. Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
b. Would the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? Sunnyvale is a primarily urbanized community with parks and recreational spaces incorporated throughout the City. About 770 acres, over 7 percent of the area within Sunnyvale’s incorporated City limits, is devoted to park and recreation facilities owned or maintained by the City for public use, including 22 neighborhood parks (176 acres) and nine special use facilities (264 acres). The City has a recreational standard of 5.2 acres per 1,000 residents, which is within the National Recreation and Park Association (NRPA) guidelines of four to six acres of open space per 1,000 residents.97 The Sunnyvale General Plan Land Use and Transportation Element and Community Character Element identify policies and actions such as Policies LT-9.1 through LT-9.9 and LT-10.1 through LT-10.4, to manage the local parks and recreational facilities and protect open space resources within Sunnyvale.98, 99
The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to parks or recreational facilities.

The Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing Plays and Moves, such as Moves 4.L and 4.M to increase trees and green stormwater infrastructure and Moves 6.B and 6.C to protect the shoreline and expand tidal and salt marshes, that are consistent with

97 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed February 2024). 98 Sunnyvale, City of. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023). 99 Sunnyvale, City of. 2011. Community Character Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/598/637819113519200000 (accessed February 2024).

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City of Sunnyvale
Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

86 Sunnyvale’s General Plan, including its recreation and open space policies. Additionally, as described in Section 14, Population and Housing, the Sunnyvale Playbook Update/Game Plan 2028 would not result in substantial population growth or direct land use changes. As such, implementation of the Sunnyvale Playbook Update/Game Plan 2028 would not result in a substantial physical deterioration of parks or other recreational facilities or result in the need to expand recreational facilities.

Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Thresholds would result in no impact related to recreation in terms of construction of or need for the construction of new or altered recreational facilities.

Cumulative Impacts
The cumulative projects scenario is the population, employment, and households forecasts identified in the supporting documentation for the Sunnyvale Playbook Update/Game Plan 2028, based on demographic data contained in Plan Bay Area 2040 (refer to Table 5). As a guidance document, the CEQA GHG Emissions Thresholds would not result in cumulative impacts related to parks and recreational facilities. Likewise, implementation of future Sunnyvale Playbook Update/Game Plan 2028 projects, in combination with other cumulative projects that occur to accommodate Sunnyvale’s anticipated population, employment, and housing growth, would not result in increases in population or induce additional population growth beyond that assumed under the Sunnyvale General Plan and 2040 population projections. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 would not result in increased demand for parks or substantial cumulative physical deterioration of parks or other recreational facilities or result in the cumulative need to expand recreational facilities. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no cumulative impact related to recreation.

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Environmental Checklist
Transportation

Final Initial Study–Negative Declaration 87
17 Transportation

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Conflict with a program, plan, ordinance or
policy addressing the circulation system,
including transit, roadway, bicycle and
pedestrian facilities? □ □ □ ■
b. Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision
(b)? □ □ □ ■
c. Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible use (e.g., farm equipment)? □ □ ■ □
d. Result in inadequate emergency access? □ □ ■ □
a. Would the project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? b. Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
The Sunnyvale General Plan Land Use and Transportation Element includes the following goals:
▪ Goal LT-1: Coordinated regional and local planning.
▪ Goal LT -2: Environmentally sustainable land use and transportation planning and development. ▪ Goal LT -3: An effective multimodal transportation system. ▪ Goal LT -4: An attractive community for residents and businesses. ▪ Goal LT -5: Creation, preservation, and enhancement of Village Centers and neighborhood facilities that are compatible with residential neighborhoods. ▪ Goal LT -6: Protected, maintained, and enhanced residential neighborhoods. ▪ Goal LT -7: Diverse housing opportunities.
▪ Goal LT -8: Options for healthy living.
▪ Goal LT -9: Adequate and balanced recreation facilities. ▪ Goal LT -10: Regional approach to providing and receiving open space. ▪ Goal LT -11: Supportive economic development environment. ▪ Goal LT -12: A balanced economic base.
▪ Goal LT -13: Protected, maintained, and enhanced commercial areas, shopping centers, and business districts.

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City of Sunnyvale
Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

88 ▪ Goal LT -14: Special and unique land uses to create a diverse and complete community.100 Additionally, the City adopted the Active Transportation Plan in 2020, which includes plans for bicycle, pedestrian, and safe routes to school programs, with a main goal to assist the City in creating a safe, connected, and efficient Citywide walking and bicycling network. The Active Transportation Plan also implements the Sunnyvale General Plan goals, policies, and actions related to complete streets by building a blueprint for a system of bikeways and pedestrian facilities across Sunnyvale.101
The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to conflict with a program, plan, ordinance, or policy addressing the transportation circulation system. The Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing strategies and policies that are consistent with the Sunnyvale Land Use and Transportation Element and Active Transportation Plan. Sunnyvale Playbook Update/Game Plan 2028 Play 3.2 facilitates the continued implementation of the Active Transportation Plan and the development of new bicycle and pedestrian facilities, including bike and pedestrian paths and bike share and scooter share. Play 3.2 also emphasizes improvements to the public transit system and first-last-mile connections to increase transit ridership. Additionally, Sunnyvale Playbook Update/Game Plan 2028 Play 3.1, along with Play 3.2, would reduce VMT within the City, aligning with the goals of the General Plan and Active Transportation Plan.

The Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves would advance active transportation and public transit within Sunnyvale and decrease VMT and associated air pollutants and GHG emissions. The Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves would be consistent with the Sunnyvale General Plan Land Use and Transportation Element and Active Transportation Plan goals related to improving multi-modal facilities, reducing VMT and single- occupancy vehicles, encouraging active transportation, and reducing vehicle congestion within Sunnyvale. Furthermore, the Sunnyvale Playbook Update/Game Plan 2028 would seek to reduce VMT within Sunnyvale, consistent with CEQA Guidelines section 15064.3, subdivision (b). Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to consistency with plans and policies addressing the transportation circulation system and CEQA Guidelines section 15064.3, subdivision (b). c. Would the project substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible use (e.g., farm equipment)? d. Would the project result in inadequate emergency access? The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to risk associated with transportation design, incompatible use, or emergency access. The Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing strategies that are consistent with the Sunnyvale General Plan, including the Land Use and Transportation Element, and would not facilitate development beyond that allowed under the General Plan. Implementation of some

100 Sunnyvale, City of. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023). 101 Sunnyvale, City of. 2020. Sunnyvale Active Transportation Plan. https://www.sunnyvale.ca.gov/home/showpublisheddocument/2844/637822670426570000 (accessed October 2023).

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Transportation

Final Initial Study–Negative Declaration 89
Sunnyvale Playbook Update/Game Plan 2028 Plays, such as Play 3.2 that would provide for new bicycle and pedestrian facilities, may involve construction within the local right-of-way. Construction activities have the potential to require lane closures and may impact traffic and vehicle speeds on the affected roadways; however, these impacts would be temporary and access to roadways would generally be maintained throughout project construction. Furthermore, future projects involving work in the public right-of-way would be required to coordinate with the City to ensure appropriate construction staging and adequate emergency access on adjacent roadways pursuant to SMC Chapter 13.08.102 Compliance with the SMC would minimize impacts related to the circulation system design, including safety impacts and emergency access, would not occur. As such, construction of Sunnyvale Playbook Update/Game Plan 2028 projects would not create transportation design hazards or result in inadequate emergency access. Furthermore, the Sunnyvale Playbook Update/Game Plan 2028 would facilitate increased active transportation and public transit use and decreased VMT within Sunnyvale, which in turn would reduce potential transportation hazards and congestion conditions that can hinder emergency response. Thus, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to transportation hazards and emergency access.

Cumulative Impacts
The cumulative projects scenario is the population, employment, and households forecasts identified in the supporting documentation for the Sunnyvale Playbook Update/Game Plan 2028, based on demographic data contained in Plan Bay Area 2040 (refer to Table 5). As a guidance document, the CEQA GHG Emissions Thresholds would not result in cumulative impacts. Cumulative projects that occur to accommodate Sunnyvale’s anticipated population, employment, and housing growth could result in increases in VMT or changes affecting traffic design safety and emergency access. However, the Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing programs that are consistent with the General Plan and other applicable transportation policies and does not propose new development that would increase VMT, result in design hazard, or affect emergency access. Rather, the Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves would promote alternative modes of transportation and reduction of VMT throughout Sunnyvale, consistent with goals contained in the General Plan Land Use and Transportation Element and Active Transportation Plan. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in an overall less-than-significant cumulative impact related to transportation.

102 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Chapter 13.08, Right-of-Way Encroachments. https://ecode360.com/42719687?highlight=encroachments&searchId=16491543957131113#42719687 (accessed February 2024).

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90 18 Tribal Cultural Resources

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a. Listed or eligible for listing in the California
Register of Historical Resources, or in a
local register of historical resources as
defined in Public Resources Code section
5020.1(k), or □ □ ■ □
b. A resource determined by the lead agency,
in its discretion and supported by
substantial evidence, to be significant
pursuant to criteria set forth in subdivision
(c) of Public Resources Code Section
2024.1. In applying the criteria set forth in
subdivision (c) of Public Resources Code
Section 5024.1, the lead agency shall
consider the significant of the resource to a
California Native American tribe? □ □ ■ □
a. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in a Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code § 5020.1 (k)? b. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in a Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 2024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency shall consider the significant of the resource to a California Native American tribe?
On January 18 and 22, 2024, the eight following Native American Heritage Commission (NAHC)- identified local Native American tribal groups were formally notified via certified mail and email that Attachment 10

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Final Initial Study–Negative Declaration 91
the City initiated environmental review of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds and were invited to provide consultation:
▪ Amah Mutsun Tribal Band
▪ Amah Mutsun Tribal Band of Mission San Juan Bautista
▪ Indian Canyon Mutsun Band of Costanoan
▪ Muwekma Ohlone Indian Tribe of the San Francisco Bay Area ▪ North Valley Yokuts Tribe
▪ Tamien Nation
▪ The Ohlone Indian Tribe
▪ Wuksache Indian Tribe/Eshom Valley Band
The City also sent follow up emails to the tribes on February 1, 2024. Under AB 52, Native American tribes have 30 days to respond and request further project information and formal consultation. The only response received was from the Amah Mutsun Tribal Band that emailed the City on February 1, 2024 indicating that the plan area is outside of the tribe’s traditional boundaries.

The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to tribal cultural resources. Likewise, the Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning changes that would increase development within the City but would instead promote sustainable infrastructure development within the urbanized area of Sunnyvale. As a policy document, the Sunnyvale Playbook Update/Game Plan 2028 would also not directly entail ground disturbing activities. However, future implementation of Sunnyvale Playbook Update/Game Plan 2028 actions related to existing building energy, active transportation, renewable energy, and tree planting may include construction activities with the potential to disturb previously undiscovered tribal cultural resources, as discussed further below.

Electrification retrofits associated with Sunnyvale Playbook Update/Game Plan 2028 Play 2.2 may change the physical environment through the need for upgraded service and electrical panels, branch circuit upgrades, installation of condensate drains to facilitate the installation of electric heat pumps for water and space heating, and ground disturbance to remove nature gas infrastructure.

The physical changes these upgrades would entail are dependent on the year of building construction and location of electrical and service panels and plumbing connection of condensate drains, which sometimes may include modifications to the interior and/or exterior of buildings for wiring and panel replacement and minor excavation for connection of drainage to sewer systems.

Sunnyvale Playbook Update/Game Plan 2028 Play 3.2 would encourage development of new bicycle and pedestrian infrastructure, which may involve construction activities to create new bike lanes and bike/pedestrian paths throughout Sunnyvale. Installation of new bike and pedestrian facilities would primarily impact previously disturbed areas within the public rights-of-way. However, the physical changes these enhancements would entail are dependent on the location of construction, which in some cases may include minor temporary excavation and grading.

Sunnyvale Playbook Update/Game Plan 2028 Plays 1.2 and 1.3 would result in the addition of solar PV and thermal energy systems, along with battery storage, within the City. These would primarily entail the installation of small-scale systems on existing developed sites. Additionally, Sunnyvale Playbook Update/Game Plan 2028 Play 4.3 seeks to plant additional trees throughout the City, Attachment 10

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92 which may require the use of construction equipment for the moving and placement of trees. These actions could result in ground disturbance related to the construction of new infrastructure and planting of new trees.

Implementation of these Sunnyvale Playbook Update/Game Plan 2028 actions could impact unknown tribal cultural resources during construction that involves below-grade activities in previously undisturbed soils. However, future Sunnyvale Playbook Update/Game Plan 2028 projects would be located and designed strategically to reduce ground disturbance to the maximum extent possible. In addition, Sunnyvale Playbook Update/Game Plan 2028 projects and actions would be reviewed for consistency with applicable local, regional, and State tribal cultural and archaeological regulations prior to final siting and construction and would be required to comply with Sunnyvale General Plan Policy LT-1.10 and Action LT-1.10f, which includes a requirement that projects halt all ground-disturbing activities when unusual amounts of shell or bone, isolated artifacts, or other similar features are discovered and retain a qualified professional to determine the significance of the finding and implement mitigation measures.103 As such, tribal cultural resources would be protected prior to and/or upon discovery and, thus, impacts would be reduced to a minimal level.

Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to tribal cultural resources.

Cumulative Impacts
The cumulative projects scenario is the population, employment, and households forecasts identified in the supporting documentation for the Sunnyvale Playbook Update/Game Plan 2028, based on demographic data contained in Plan Bay Area 2040 (refer to Table 5). As a guidance document, the CEQA GHG Emissions Thresholds would not result in construction projects and would not affect tribal cultural resources. Future Sunnyvale Playbook Update/Game Plan 2028 projects, in combination with other cumulative projects that occur to accommodate Sunnyvale’s anticipated population, employment, and housing growth, could increase the potential for adverse effects to unknown tribal cultural resources in Sunnyvale. However, impacts to tribal cultural resources are site-specific; accordingly, as required under applicable laws and regulations, potential impacts associated with cumulative developments would be addressed on a case-by-case basis as cumulative project details and locations become known. Sunnyvale Playbook Update/Game Plan 2028 projects and other cumulative projects would be required to comply with Sunnyvale General Plan Policy LT-1.10 and Action LT-1.10f, for the protection and proper treatment of any cultural resources discovered during ground disturbance, which would minimize the potential for significant impacts to tribal cultural resources. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant cumulative impact related to tribal cultural resources.

103 Sunnyvale, City of. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023).

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Final Initial Study–Negative Declaration 93
19 Utilities and Service Systems

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects? □ □ ■ □
b. Have sufficient water supplies available to
serve the project and reasonably
foreseeable future development during
normal, dry and multiple dry years? □ □ □ ■
c. Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it has
adequate capacity to serve the project’s
projected demand in addition to the
provider’s existing commitments? □ □ □ ■
d. Generate solid waste in excess of State or
local standards, or in excess of the capacity
of local infrastructure, or otherwise impair
the attainment of solid waste reduction
goals? □ □ □ ■
e. Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste? □ □ □ ■
a. Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
The Sunnyvale Playbook Update/Game Plan 2028 is a policy document aimed at reducing water, solid waste, and energy consumption and related GHG emissions and does not propose development or changes to land use and zoning designations or include site-specific infrastructure designs or project proposals. Furthermore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 would not result in an increase in population and housing, nor would it facilitate growth beyond that anticipated by the Sunnyvale General Plan and 2040 Plan Bay Area Attachment 10

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94 projections. As such, implementing the Sunnyvale Playbook Update/Game Plan 2028 would not create new demand related to water, wastewater, stormwater drainage, electric power, natural gas power, or telecommunications utilities. However, projects resulting from implementation of the Sunnyvale Playbook Update/Game Plan 2028 could include redevelopment and/or restructuring of electricity and natural gas power facilities and infrastructure, as well as new local renewable energy generation and storage and water infrastructure projects. Potential impacts related to these strategies are discussed further as follows by utility facilities topic.

Water Supply Facilities/Infrastructure
Sunnyvale has three sources of potable water supply: surface water from the San Francisco Public Utilities Commission (SFPUC), treated surface water from the Santa Clara Valley Water District (SCVWD), and groundwater. Recycled water produced at the City’s Water Pollution Control Plant (WPCP) makes up the remaining part of the water portfolio.104 The Sunnyvale 2020 Urban Water Management Plan projects that the City will have adequate water supplies for normal, single dry year, and multiple dry year scenarios through 2040.105
The Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would not result in new land uses that would contribute to an increase in water use compared to existing conditions. Rather, Sunnyvale Playbook Update/Game Plan 2028 Play 4.2 seeks to decrease water consumption and increase the resilience of the Sunnyvale water supplies. In addition, Sunnyvale Playbook Update/Game Plan 2028 Play 4.3 would increase green stormwater infrastructure in the City, improving water infiltration and groundwater recharge. As such, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in reduced water use and, thus, relocation or construction of new or expanded water facilities would not be required.

Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to need for the construction or expansion of water supply facilities and infrastructure.

Wastewater Treatment Facilities/Infrastructure
The City owns and operates the Donald M. Sommers Water Pollution Control Plant located at 1444 Borregas Avenue in Sunnyvale. The Water Pollution Control Plant treats wastewater from residential, commercial, and industrial sources in Sunnyvale, the Rancho Rinconada portion of Cupertino, and Moffett Federal Airfield. Treated wastewater is discharged to the southern San Francisco Bay via the Guadalupe Slough. Five major trunk networks terminate at the WPCP, referred to as the Lawrence, Borregas, Lockheed, Moffett, and Cannery trunks.106 The Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would not result in new land uses that would generate sanitary wastewater or otherwise contribute to an increase in wastewater treatment requirements. The amount or characteristics of wastewater treated at the WPCP or by the City of Sunnyvale would not change compared to existing conditions. As such, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would not only reduce water use but also not require relocation or construction of new wastewater collection or treatment infrastructure. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG

104 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed February 2024). 105 Sunnyvale, City of. 2021. 2020 Urban Water Management Plan. https://www.sunnyvale.ca.gov/home/showpublisheddocument/380/637889141541470000 (accessed March 2024). 106 Ibid
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Final Initial Study–Negative Declaration 95
Emissions Thresholds would result in no impact related to need for the construction or expansion of wastewater facilities and infrastructure.

Stormwater Drainage Facilities/Infrastructure
The City of Sunnyvale maintains a system of storm drains, gutters, and ditches to convey stormwater generated during rain events. As discussed in Section 10, Hydrology and Water Quality, the Sunnyvale Playbook Update/Game Plan 2028 does not propose development or changes to land use and zoning designations and, thus, would not have direct construction or operational impacts related to stormwater drainage facilities. Implementation of Sunnyvale Playbook Update/Game Plan 2028 Plays 1.2, 1.3, 2.2, 3.2, 3.3, and 4.3 related to building electrification, renewable energy production and storage, transportation, water, and urban trees may promote infrastructure development that would involve small-scale construction. Construction of projects implemented in accordance with the Sunnyvale Playbook Update/Game Plan 2028 could result in erosion and potential changes to drainage patterns. However, as described in Section 7, Geology and Soils, and Section 10, Hydrology and Water Quality, Sunnyvale Playbook Update/Game Plan 2028 projects would be required to comply with local, State, and federal requirements during construction that would reduce stormwater runoff, erosion, and potential impacts to the stormwater drainage system. Furthermore, Sunnyvale Playbook Update/Game Plan 2028 Play 4.3 encourages the development of green stormwater infrastructure in the City, which would help to reduce stormwater flows to the City’s drainage facilities. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to need for the construction or expansion of stormwater drainage facilities and infrastructure.

Electric Power Facilities/Infrastructure
Electric power service in the City is provided by SVCE using transmission infrastructure operated and maintained by Pacific Gas & Electric (PG&E). The Sunnyvale Playbook Update/Game Plan 2028 would not involve new land uses or development that require new or additional electric service.

Sunnyvale Playbook Update/Game Plan 2028 Play 1.1 promotes the use of SVCE-supplied energy to increase the use of clean electricity, with a goal of 100 percent clean energy participation by 2030.

Plays 1.2 and 1.3 support installation of small-scale solar PV and renewable energy systems and battery storage facilities throughout the City to provide greener renewable electricity. Sunnyvale Playbook Update/Game Plan 2028 Plays 2.1 through 2.3 promote energy efficiency upgrades and electrification of new and existing buildings. In addition, Play 3.3 encourages new EV infrastructure throughout the City. These Plays may alter electricity demand within Sunnyvale. However, the Sunnyvale Playbook Update/Game Plan 2028 would serve as a pathway to reduce GHG emissions, including emissions related to energy consumption, and other beneficial environmental and sustainability effects. These benefits include a reduction in energy consumption. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to construction, expansion, or relocation of electric power facilities and infrastructure.

Natural Gas Power Facilities/Infrastructure
PG&E provides natural gas services to Sunnyvale. The Sunnyvale Playbook Update/Game Plan 2028 would not involve new land uses that require new or additional natural gas service that could require the construction of new or expanded natural gas facilities. Sunnyvale Playbook Update/Game Plan 2028 Plays 2.2 and 2.3 would encourage or require building electrification in Attachment 10

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96 new and existing buildings to reduce natural gas consumption within the City. Implementation of these actions could involve minor alterations to existing natural gas infrastructure as natural gas use is reduced. However, the Sunnyvale Playbook Update/Game Plan 2028 would serve as a pathway to reduce GHG emissions, including emissions related to energy consumption, and other beneficial environmental and sustainability effects. These benefits include a reduction in natural gas consumption. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to construction, removal, or relocation of natural gas power facilities and infrastructure.

Telecommunications Facilities/Infrastructure
Sunnyvale is served by existing telecommunications companies such as AT&T and Comcast. The Sunnyvale Playbook Update/Game Plan 2028 would not alter existing telecommunications facilities and infrastructure and would not involve new land uses or development that would require new telecommunications infrastructure. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 would result in no impact related to need for construction or expansion of telecommunication facilities and infrastructure.

Overall, the Sunnyvale Playbook Update/Game Plan 2028 would result in a less-than-significant impact related to need for construction, relocation, or expansion of utilities. b. Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? c. Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to water supplies or wastewater.

Sunnyvale Playbook Update/Game Plan 2028 is a policy-level document that does not propose development or changes to land use and zoning designations or include site-specific infrastructure designs or project proposals, nor does it grant entitlements for development that would have the potential to increase demand for water supply or wastewater treatment. Rather the Sunnyvale Playbook Update/Game Plan 2028 contains Plays and Moves to reduce water use, such as Play 4.2, which includes actions to require water efficient fixtures and landscaping irrigation, promote graywater use, and education the community on water conservation, and Play 4.3, which would increase green stormwater infrastructure and groundwater infiltration in the City. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to water supply and wastewater treatment. d. Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
e. Would the project comply with federal, State, and local management and reduction statutes and regulations related to solid waste?
The City contracts with Specialty Solid Waste and Recycling to provide solid waste collection services to residents and businesses in Sunnyvale. Collected waste is transported to the Sunnyvale Materials Attachment 10

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Final Initial Study–Negative Declaration 97
Recovery and Transfer Station, where it is sorted to remove recyclable materials from mixed waste and prepare them and source-separated recyclables and compostable materials for shipment to markets. The City of Sunnyvale has an agreement for solid waste disposal with Waste Management of California that currently directs the City’s waste to the Kirby Canyon Landfill. If, in the future, Waste Management of California closed the Kirby Canyon Landfill, Waste Management would be required to provide Sunnyvale disposal capacity at an alternative disposal site.107 The Kirby Canyon Landfill has a remaining capacity of 16,191,600 cubic yards with a maximum daily throughput of 2,600 tons of waste and is permitted to operate through 2059.108 The Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds do not propose development or changes to land use and zoning designations and would not facilitate increased development and, thus, would not result in an increase in solid waste collection and disposal demand. Rather, the Sunnyvale Playbook Update/Game Plan 2028 includes Play 4.1, which would reduce solid waste production, increase the diversion of organic and food waste, and increase participation in recycling programs in order to minimize waste being sent to the landfill.

Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to solid waste.

Cumulative Impacts
The cumulative projects scenario is the population, employment, and households forecasts identified in the supporting documentation for the Sunnyvale Playbook Update/Game Plan 2028, based on demographic data contained in Plan Bay Area 2040 (refer to Table 5). As a guidance document, the CEQA GHG Emissions Thresholds would not result in cumulative impacts. Other cumulative projects that occur to accommodate Sunnyvale’s anticipated population, employment, and housing growth could result in increases in population and additional use of or need for utilities and service systems. However, implementation of the CEQA GHG Emissions Thresholds and Sunnyvale Playbook Update/Game Plan 2028 and related infrastructure projects would not contribute to increases in population or induce additional population growth that would require additional use of existing utilities or service systems. Rather, implementation of the Sunnyvale Playbook Update/Game Plan 2028 would result in reduced energy and water consumption and solid waste and wastewater generation. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 CEQA GHG Emissions Thresholds would result in an overall less-than- significant cumulative impact related to utilities and service systems.

107 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed February 2024). 108 CalRecycle. 2024. Kirby Canyon Recycle and Disposal Facility. https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1370?siteID=3393 (accessed February 2024).

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98 20 Wildfire

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a. Substantially impair an adopted
emergency response plan or emergency
evacuation plan? □ □ □ ■
b. Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks and
thereby expose project occupants to
pollutant concentrations from a wildfire
or the uncontrolled spread of a wildfire? □ □ □ ■
c. Require the installation or maintenance
of associated infrastructure (such as
roads, fuel breaks, emergency water
sources, power lines or other utilities)
that may exacerbate fire risk or that may
result in temporary or ongoing impacts
to the environment? □ □ □ ■
d. Expose people or structures to significant
risks, including downslopes or
downstream flooding or landslides, as a
result of runoff, post-fire slope instability,
or drainage changes? □ □ □ ■
a. If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
b. If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project due to slope, prevailing winds, and other factors, exacerbate wildfire risks and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
c. If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? Attachment 10

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Final Initial Study–Negative Declaration 99
d. If located in or near State responsibility areas or lands classified as very high fire hazard severity zones, would the project expose people or structures to significant risks, including downslopes or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
According to the California Department of Forestry and Fire Protection (CalFIRE), the City is not located in a Local Responsibility Area or State Responsibility Area Fire Hazard Severity Zones.109 The nearest Very High Fire Hazard Severity Zone (VHFHSZ) is located within southern Cupertino, approximately 2.4 miles south of the Sunnyvale City limits at its closest point. According to the Santa Clara Operational Area Hazard Mitigation Plan-Sunnyvale Annex, Sunnyvale is urbanized and categorized as having no risk of wildland fire.110
The Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds are policy- level documents that do not propose new residential, commercial, or institutional development that could be at risk from wildfire, nor do they grant entitlements for development that would have the potential to directly cause wildfire. Rather, these documents would aim to reduce Sunnyvale’s contributions to and vulnerability to the effects of climate change, such as drought and flooding.

Thus, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to wildfire exposure, exacerbation, or related emergency evacuation.

109 California Department of Forestry and Fire Protection (CalFIRE). 2023. Fire Hazard Severity Zone Viewer. https://egis.fire.ca.gov/FHSZ/ (accessed October 2023). 110 County of Santa Clara. 2017. Santa Clara Operational Area Hazard Mitigation Plan; Volume 2—Partner Annexes. https://sunnyvaleca.legistar.com/LegislationDetail.aspx?ID=3216998&GUID=7E0A85F2-3134-4300-B6FC-DF5ACC14A82C&FullText=1 (accessed February 2024).

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100
21 Mandatory Findings of Significance

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Does the project:
a. Have the potential to substantially degrade
the quality of the environment,
substantially reduce the habitat of a fish or
wildlife species, cause a fish or wildlife
population to drop below self-sustaining
levels, threaten to eliminate a plant or
animal community, substantially reduce
the number or restrict the range of a rare
or endangered plant or animal or eliminate
important examples of the major periods
of California history or prehistory? □ □ ■ □
b. Have impacts that are individually limited,
but cumulatively considerable?
(“Cumulatively considerable” means that
the incremental effects of a project are
considerable when viewed in connection
with the effects of past projects, the effects
of other current projects, and the effects of
probable future projects)? □ □ ■ □
c. Have environmental effects which will
cause substantial adverse effects on
human beings, either directly or indirectly? □ □ ■ □
a. Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? The intent of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds is to reduce GHG emissions from Sunnyvale community operations through implementation of Plays and Moves related to energy use, water consumption, transportation, solid waste, and carbon sequestration. The Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds are consistent with the Sunnyvale General Plan and encourage residents, businesses, and institutions to reduce energy and water use, fuel use, VMT, and solid waste generation and the associated GHG emissions. The Sunnyvale Playbook Update/Game Plan 2028 would not facilitate development that would eliminate or threaten wildlife habitats or eliminate important examples of the major periods of California history or prehistory. Therefore, as discussed in more detail in Attachment 10

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Environmental Checklist
Mandatory Findings of Significance

Final Initial Study–Negative Declaration 101
Section 4, Biological Resources, Section 5, Cultural Resources, and Section 18, Tribal Cultural Resources, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in an overall less-than-significant impact related to biological and cultural resources. b. Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? Implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a cumulatively beneficial reduction of GHG and air pollutant emissions across Sunnyvale. In addition, as discussed throughout the respective cumulative impacts discussions within this document, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would not result in significant cumulative impacts. Rather, implementation of the Sunnyvale Playbook Update/Game Plan 2028 would be consistent with the Sunnyvale General Plan policies aimed at reducing emissions of GHGs and air pollutants, VMT, energy and water supply demands on utilities, and solid waste generation. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in an overall less-than-significant cumulative impact related to the various CEQA topics addressed within this document. c. Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
In general, impacts to human beings are associated with air quality, GHG emissions, hazards and hazardous materials, noise, transportation, and wildfire impacts. As detailed in the preceding sections, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would not result, either directly or indirectly, in substantial adverse effects related to air quality, GHG emissions, hazards, noise, transportation, or wildfire. As discussed in more detail in Section 3, Air Quality, Section 13, Noise, and Section 17, Transportation, the Sunnyvale Playbook Update/Game Plan 2028 could cause temporary construction impacts related to transportation, air quality, and noise that could, in turn, affect human beings but would not result in substantial adverse effects. In addition, as discussed throughout this document, the Sunnyvale Playbook Update/Game Plan 2028 would serve as a pathway to reduce operational GHG emissions and would result in other positive environmental and sustainability effects. These benefits include reduction in building energy and water consumption, VMT, and solid waste generation, as well as improved air quality and resiliency to the effects of climate change and natural disasters. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in an overall less-than-significant impact related to potential for adverse effects on human beings.

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Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

102
References
List of Citations
Association of Bay Area Governments and Metropolitan Transportation Commission (ABAG-MTC). 2021. Plan Bay Area 2050. https://www.planbayarea.org/finalplan2050 (accessed November 2023).

Bay Area Air Quality Management District (BAAQMD). 2017. Air Quality Standards and Attainment Status. http://www.baaqmd.gov/research-and-data/air-quality-standards-and-attainment- status (accessed December 2023).
______. 2017. Final Clean Air Plan: Spare the Air Cool the Climate: A Blueprint for Clean Air and Climate Protection in the Bay Area. Final 2017 Clean Air Plan. https://www.baaqmd.gov/plans-and-climate/air-quality-plans/current-plans (accessed December 2023).
______. 2022. CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans. https://www.baaqmd.gov/~/media/files/planning-and- research/ceqa/ceqa-guidelines-2022/appendix-b-thresholds-for-evaluating-significance-of- climate-impacts_final-pdf.pdf?la=en (accessed November 2023).

California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. https://www.aqmd.gov/docs/default-source/ceqa/handbook/california- air-resources-board-air-quality-and-land-use-handbook-a-community-health- perspective.pdf (accessed December 2023).
______. 2017 Climate Change Scoping Plan.
https://ww2.arb.ca.gov/sites/default/files/classic//cc/scopingplan/scoping_plan_2017.pdf (accessed November 2023).
______. 2022 Scoping Plan for Achieving Carbon Neutrality. https://ww2.arb.ca.gov/sites/default/files/2022-12/2022-sp.pdf (accessed November 2023). ______. 2022. 2022 State Strategy for the State Implementation Plan. https://ww2.arb.ca.gov/sites/default/files/2022-08/2022_State_SIP_Strategy.pdf (accessed November 2023).
______. 2023. SB 375 Regional Plan Climate Targets. https://ww2.arb.ca.gov/our- work/programs/sustainable-communities-program/regional-plan-targets (accessed November 2023).

CARB and California Environmental Protection Agency (CalEPA). 2009. Environmental Health and Equity Impacts from Climate Change and Mitigation Policies in California: A Review of the Literature. https://www.researchgate.net/profile/Seth-
Shonkoff/publication/237420289_ENVIRONMENTAL_HEALTH_AND_EQUITY_IMPACTS_FRO M_CLIMATE_CHANGE_AND_MITIGATION_POLICIES_IN_CALIFORNIA_A_REVIEW_OF_THE_LI TERATURE/links/0deec533acf69321ea000000/ENVIRONMENTAL-HEALTH-AND-EQUITY-

IMPACTS-FROM-CLIMATE-CHANGE-AND-MITIGATION-POLICIES-IN-CALIFORNIA-A-REVIEW- OF-THE-LITERATURE.pdf (accessed February 2024).

Attachment 10

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References

Final Initial Study–Negative Declaration 103
California Department of Conservation. 2023. California Important Farmland Finder Map. https://maps.conservation.ca.gov/dlrp/ciff/ (accessed December 2023).

California Department of Finance (DOF). 2023. E-5 Population and Housing Estimates. https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing- estimates-for-cities-counties-and-the-state-2020-2023/ (accessed November 2023).

California Department of Forestry and Fire Protection (CalFIRE). 2023. Fire Hazard Severity Zone Viewer. https://egis.fire.ca.gov/FHSZ/ (accessed October 2023).

California Department of Transportation (Caltrans). 2018. California State Scenic Highway System Map.
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e 8057116f1aacaa (accessed December 2023).
______. 2020. Transportation and Construction Vibration Guidance Manual (CT-HWANP-RT-13- 069.25.3). https://dot.ca.gov/-/media/dot-media/programs/environmental- analysis/documents/env/tcvgm-apr2020-a11y.pdf (accessed February 2024).

California Energy Commission (CEC). 2023. Electricity Consumption by County. http://www.ecdms.energy.ca.gov/elecbycounty.aspx (accessed October 2023). ______. 2023. Gas Consumption by County. http://www.ecdms.energy.ca.gov/gasbycounty.aspx (accessed October 2023).

California Geological Survey. 2023. Earthquake Zones of Required Investigation. https://maps.conservation.ca.gov/cgs/EQZApp/app/ (accessed October 2023).

CalRecycle. 2024. Kirby Canyon Recycle and Disposal Facility. https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1370?siteID=3393 (accessed February 2024).

Federal Highway Administration (FHWA). 2006. FHWA Highway Construction Noise Handbook. (FHWAHEP-06-015; DOT-VNTSC-FHWA-06-02).
https://www.fhwa.dot.gov/Environment/noise/construction_noise/handbook/handbook00. cfm (accessed February 2024).

Federal Transit Administration. 2018. Transit Noise and Vibration Impact Assessment Manual. https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research- innovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta-report-no- 0123_0.pdf (accessed February 2024).

Rincon Consultants, Inc. 2023. Sunnyvale 2019 Community Inventory Memorandum. February 6, 2023.
______. 2023. Sunnyvale Playbook Update GHG Forecast Report. February 2023.

Santa Clara County. 2017. Santa Clara Operational Area Hazard Mitigation Plan; Volume 2—Partner Annexes.
https://sunnyvaleca.legistar.com/LegislationDetail.aspx?ID=3216998&GUID=7E0A85F2 - 3134-4300-B6FC-DF5ACC14A82C&FullText=1 (accessed February 2024). ______. 2022. Williamson Act Properties.
https://sccplanning.maps.arcgis.com/apps/webappviewer/index.html?id=1f39e32b4c0644b 0915354c3e59778ce (accessed December 2023).

Attachment 10

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Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

104
______. 2023. Climate Roadmap 2030. https://sustainability.sccgov.org/climate-roadmap-2030 (accessed November 2023).

State of California. 2019. California’s Fourth Climate Change Assessment Statewide Summary Report. http://www.climateassessment.ca.gov/state/ (accessed February 2024).

Sunnyvale, City of. 2011. Community Character Element.
https://www.sunnyvale.ca.gov/home/showpublisheddocument/598/637819113519200000 (accessed January 2024).
______. 2011. General Plan Safety and Noise Element.
https://www.sunnyvale.ca.gov/home/showpublisheddocument/602/638370338402370000 (accessed February 2024).
______. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed November 2023).
______. 2018. Heritage Resources Inventory.
https://www.sunnyvale.ca.gov/home/showpublisheddocument/1556/63782085091527000 0 (accessed January 25, 2024).
______. 2020. Sunnyvale Active Transportation Plan.
https://www.sunnyvale.ca.gov/home/showpublisheddocument/2844/63782267042657000 0 (accessed October 2023).
______. 2021. Nonresidential and Multifamily Residential Reach Codes. https://www.sunnyvale.ca.gov/home/showpublisheddocument/1496/63782084752027000 0 (accessed November 2023).
______. 2021. 2020 Urban Water Management Plan.
https://www.sunnyvale.ca.gov/home/showpublisheddocument/380/637889141541470000 (accessed March 2024).______. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023).
______. 2023. Single-Family, Duplex, and Townhome Reach Codes. https://www.sunnyvale.ca.gov/home/showpublisheddocument/1780/63811447601866293 6 (accessed November 2023).
______. 2023. Draft Sunnyvale Playbook Update/Game Plan 2028. https://www.sunnyvale.ca.gov/home/showpublisheddocument/5082/638430745425470000 (accessed February 2024).
______. 2023. Design Guidelines, Standards, and Specific Plans. https://www.sunnyvale.ca.gov/business-and-development/planning-and-building/permit- center/design-guidelines-standards-and-specific-plans (accessed December 2023). ______. 2023. Sunnyvale Municipal Code Section 19.42.050. https://ecode360.com/42730956 (accessed December 2023).
______. 2023. Sunnyvale Municipal Code Chapter 19.80.
https://ecode360.com/42732806#42732806 (accessed December 2023). ______. 2023. Sunnyvale Municipal Code Chapter 19.96, Heritage Preservation. https://ecode360.com/42733144#42733144 (accessed December 2023).

Attachment 10

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References

Final Initial Study–Negative Declaration 105
______. 2024. Sunnyvale Municipal Code Chapter 12.60, Stormwater Management. https://ecode360.com/42718251#42718251 (accessed January 2024). ______. 2024. Sunnyvale Municipal Code Chapter 13.08, Right-of-Way Encroachments. https://ecode360.com/42719687?highlight=encroachments&searchId=1649154395713111 3#42719687 (accessed February 2024).
______. 2024. Sunnyvale Municipal Code Section 16.08.030, Hours of construction—Time and noise limitations.
https://ecode360.com/42720748?highlight=&searchId=16742406866224120#42720748 (accessed February 2024).
______. 2024. Sunnyvale Municipal Code Chapter 16.16, Building Code. https://ecode360.com/42720766?highlight=&searchId=16482460774455457#42720766 (accessed February 2024).
______. 2024. Sunnyvale Municipal Code Section 18.12.100, Grading. https://ecode360.com/42728788?highlight=&searchId=16481596759239067#42728788 (accessed February 2024).
______. 2024. Sunnyvale Municipal Code Section 18.20.100, Final or parcel map—Action before filing.
https://ecode360.com/42728788?highlight=&searchId=16481596759239067#42728788 (accessed February 2024).
______. 2024. Sunnyvale Municipal Code Section 19.42.030, Noise or sound level. https://ecode360.com/42730950?highlight=&searchId=16742807840881719#42730950 (accessed February 2024).
______. 2024. Sunnyvale Municipal Code Section 19.42.060, Ground vibration regulated. https://ecode360.com/42730957?highlight=&searchId=16744449726465578#42730957 (accessed February 2024).
______. 2024. Sunnyvale Municipal Code Chapter 19.94, Tree Preservation. https://ecode360.com/42733058#:~:text=It%20is%20unlawful%20to%20damage,a%20prot ected%20tree%20removal%20permit.&text=%C2%A7%2019.94.,- 050%20Permits%20required (accessed January 2024).
______. 2024. Draft CEQA GHG Emissions Thresholds.
______. N.d. Bird-Safe Building Design Guidelines.
https://www.sunnyvale.ca.gov/home/showpublisheddocument/1542/63827343833313000 0 (accessed May 2024).

U.S. Energy Information Administration (USEIA). 2023. “California - Profile Overview.” https://www.eia.gov/state/?sid=CA.(accessed October 2023).

Valley Transportation Authority (VTA). 2014. Valley Transportation Plan 2040. http://vtaorgcontent.s3-us-west-

1.amazonaws.com/Site_Content/VTP2040_final_hi%20res_030315.pdf (accessed November 2023).
______. 2023. Valley Transportation Plan (VTP) 2050 webpage. https://www.vta.org/projects/valley-transportation-plan-vtp-2050 (accessed November 2023).

Attachment 10

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Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

106
Weather Spark. 2023. Climate and Average Weather Year Round in Sunnyvale. https://weatherspark.com/y/571/Average-Weather-in-Sunnyvale-California-United-States- Year-Round#:~:text=Over%20the%20course%20of%20the,or%20above%2087%C2%B0F (accessed November 2023).

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References

Final Initial Study–Negative Declaration 107
List of Document Preparers
Rincon prepared this Sunnyvale Playbook Update-Game Plan 2028 and CEQA GHG Emissions Thresholds Initial Study-Negative Declaration under contract to the City of Sunnyvale. Persons involved in data gathering, environmental impact analysis, quality review, graphics preparation, and document formatting include the following.

RINCON CONSULTANTS, INC.

Kelsey Bennett, Principal-in-Charge
Emily Marino, Project Manager
Nichole Yee, Environmental Planner
Dario Campos, Document Formatting Specialist
Chris Jackson Jordan, Graphics Specialist

Attachment 10

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Appendix A
Sources, Health Effects, and Typical Controls Associated with Criteria Pollutants

Attachment 10

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Sources, Health Effects, and Typical Controls Associated with Criteria Pollutants

Draft Initial Study–Negative Declaration A-1
Sources, Health Effects, and Typical Controls Associated with Criteria Pollutants Pollutant Sources Health Effects Typical Controls
Ozone (O3) Formed when reactive organic
gases (ROG) and nitrogen
oxides react in the presence of
sunlight. ROG sources include
any source that burns fuels
(e.g., gasoline, natural gas,
wood, oil); solvents;
petroleum processing and
storage.

Breathing difficulties, lung
tissue damage, vegetation
damage, damage to rubber
and some plastics.

Reduce motor vehicle reactive
organic gas (ROG) and
nitrogen oxide (NOX) emissions
through emission standards,
reformulated fuels,
inspections programs, and
reduced vehicle use. Limit
ROG emissions from
commercial operations,
gasoline refueling facilities,
and consumer products. Limit
ROG and NOX emissions from
industrial sources such as
power plants and
manufacturing facilities.

Carbon monoxide
(CO)
Any source that burns fuel
such as automobiles, trucks,
heavy construction and
farming equipment, residential
heating.

Chest pain in heart patients,
headaches, reduced mental
alertness.

Control motor vehicle and
industrial emissions. Use
oxygenated gasoline during
winter months. Conserve
energy
Nitrogen dioxide
(NO2)
See Carbon Monoxide. Lung irritation and damage.

Reacts in the atmosphere to
form ozone and acid rain.

Control motor vehicle and
industrial combustion
emissions. Conserve energy.

Sulfur dioxide
(SO2)
Coal or oil burning power
plants and industries,
refineries, diesel engines.

Increases lung disease and
breathing problems for
asthmatics. Reacts in the
atmosphere to form acid rain.

Reduce use of high sulfur fuels
(e.g., use low sulfur
reformulated diesel or natural
gas). Conserve energy.

Respirable
particulate matter
(PM10)
Road dust, windblown dust,
agriculture and construction,
fireplaces. Also formed from
other pollutants (NOX, SOX,
organics).

Increased respiratory disease,
lung damage, cancer,
premature death, reduced
visibility, surface soiling.

Control dust sources,
industrial particulate
emissions, woodburning
stoves and fireplaces. Reduce
secondary pollutants which
react to form PM10. Conserve
energy.

Fine particulate
matter (PM2.5)
Fuel combustion in motor
vehicles, equipment, and
industrial sources; residential
and agricultural burning. Also
formed from reaction of other
pollutants (NOX, SOX, organics,
and NH3).

Increases respiratory disease,
lung damage, cancer, and
premature death, reduced
visibility, surface soiling.

Particles can aggravate heart
diseases such as congestive
heart failure and coronary
artery disease.

Reduce combustion emissions
from motor vehicles,
equipment, industries, and
agricultural and residential
burning. Precursor controls,
like those for ozone, reduce
fine particle formation in the
atmosphere.

Lead Metal smelters, resource
recovery, leaded gasoline,
deterioration of lead paint.

Learning disabilities, brain and
kidney damage. Control metal
smelters.

No lead in gasoline or paint.

Sulfur Dioxide
(SO2)
Coal or oil burning power
plants and industries,
refineries, diesel engines.

Increases lung disease and
breathing problems for
asthmatics. Reacts in the
atmosphere to form acid rain.

Reduce use of high sulfur fuels
(e.g., use low sulfur
reformulated diesel or natural
gas). Conserve energy.

Sulfates Produced by reaction in the air
of SO2, (see SO2 sources), a
component of acid rain.

Breathing difficulties,
aggravates asthma, reduced
visibility.

See SO2
Attachment 10

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City of Sunnyvale
Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

A-2
Pollutant Sources Health Effects Typical Controls
Hydrogen Sulfide Geothermal power plants,
petroleum production and
refining, sewer gas.

Nuisance odor (rotten egg
smell), headache and
breathing difficulties (higher
concentrations).

Control emissions from
geothermal power plants,
petroleum production and
refining, sewers, and sewage
treatment plants.

Visibility Reducing
Particulates
See PM2.5 Reduced visibility (e.g.,
obscures mountains and other
scenery), reduced airport
safety.

See PM2.5
Vinyl Chloride Exhaust gases from factories
that manufacture or process
vinyl chloride (construction,
packaging, and transportation
industries).

Central nervous system effects
(e.g., dizziness, drowsiness,
headaches), kidney irritation,
liver damage, liver cancer.

Control emissions from plants
that manufacture or process
vinyl chloride, installation of
monitoring systems.

Toxic Air
Contaminant
(TAC)
Combustion engines
(stationary and mobile), diesel
combustion, storage and use
of TAC-containing substances
(i.e., gasoline, lead smelting,
etc.)
Depends on TAC, but may
include cancer, mutagenic
and/or teratogenic effects,
other acute or chronic health
effects.

Toxic Best Available Control
Technologies (T-BACT), limit
emissions from known
sources.

Source: Compiled by Rincon Consultants, Inc. in January 2024 Attachment 10

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Appendix B
Description of Greenhouse Gases of California Concern

Attachment 10

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Attachment 10

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Description of Greenhouse Gases of California Concern

Draft Initial Study–Negative Declaration B-1
Description of Greenhouse Gases of California Concern
Greenhouse Gas
Physical Description and
Properties
Global Warming
Potential
(100 years)
Atmospheric
Residence
Lifetime
(years) Sources
Carbon dioxide
(CO2)
Odorless, colorless, natural gas. 1 50–200 Burning coal, oil, natural gas, and wood; decomposition of
dead organic matter;
respiration of bacteria, plants,
animals, and fungus; oceanic
evaporation; volcanic
outgassing; cement
production; land use changes
Methane
(CH4)
Flammable gas and is the main
component of natural gas.
28 12 Geological deposits (natural
gas fields) extraction; landfills;
fermentation of manure; and
decay of organic matter
Nitrous oxide
(N2O)
Nitrous oxide (laughing gas) is a
colorless GHG.
298 114 Microbial processes in soil and
water; fuel combustion;
industrial processes
Chloro-fluoro-
carbons
(CFCs)
Nontoxic, nonflammable,
insoluble, and chemically
unreactive in the troposphere
(level of air at the Earth’s
surface); formed synthetically by
replacing all hydrogen atoms in
methane or ethane with
chlorine and/or fluorine atoms.
3,800–8,100 45–640 Refrigerants aerosol
propellants; cleaning solvents.

Hydro-fluoro-
carbons
(HFCs)
Synthetic human‐made
chemicals used as a substitute
for CFCs and contain carbon,
chlorine, and at least one
hydrogen atom.
140 to 11,700 1–50,000 Automobile air conditioners;
refrigerants
Per-fluoro-
carbons (PFCs)
Stable molecular structures and
only break down by ultraviolet
rays about 60 kilometers above
Earth’s surface.
6,500 to 9,200 10,000–50,000 Primary aluminum production; semiconductor manufacturing
Sulfur
hexafluoride
(SF6)
Human‐made, inorganic,
odorless, colorless, and
nontoxic, nonflammable gas.
22,800 3,200 Electrical power transmission
equipment insulation;
magnesium industry,
semiconductor manufacturing;
a tracer gas
Nitrogen
trifluoride
(NF3)
Inorganic, is used as a
replacement for PFCs, and is a
powerful oxidizing agent.
17,200 740 Electronics manufacture for
semiconductors and liquid
crystal disPlays.

Source: Compiled by Rincon Consultants, Inc. in January 2024

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State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Bay Delta Region
2825 Cordelia Road, Suite 100
Fairfield, CA 94534
(707) 428-2002
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
May 6, 2024
Madeline Khair, Environmental Programs Manager
City of Sunnyvale
456 W Olive Avenue
Sunnyvale, CA 94086
[email protected]
Subject: Sunnyvale Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds, Initial Study/Negative Declaration, SCH No. 2024040387, City of Sunnyvale, Santa Clara County Dear Ms. Khair:

The California Department of Fish and Wildlife (CDFW) received a Notice of Intent to Adopt an Initial Study/Negative Declaration (IS/ND) from the City of Sunnyvale (City) for the Sunnyvale Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds (Project) pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines.1 CDFW is submitting comments on the draft IS/ND as a means to inform the City of Sunnyvale as the Lead Agency, of potentially significant impacts to biological resources associated with the Project.

Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife.

Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW ROLE
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State. (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub. Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a)). CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species. (Id., § 1802.) Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect fish and wildlife resources.

1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The “CEQA Guidelines” are found in Title 14 of the California Code of Regulations, commencing with section 15000.

DocuSign Envelope ID: 77413C10-952C-45EE-8359-8A56DF9D65D7 Attachment 10

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Madeline Khair
City of Sunnyvale
May 6, 2024

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CDFW is also submitting comments as a Responsible Agency under CEQA. (Pub.

Resources Code, § 21069; CEQA Guidelines, § 15381). CDFW expects that it may need to exercise regulatory authority over the Project pursuant to the Fish and Game Code. For example, the Project may be subject to CDFW’s Lake and Streambed Alteration (LSA) regulatory authority, if the Project impacts the bed, channel or bank of any river, stream or lake within the State (Fish & G. Code, § 1600 et seq.). Likewise, to the extent the Project may result in “take” as defined by state law of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), the Project proponent may seek related take authorization as provided by the Fish and Game Code.

REGULATORY REQUIREMENTS
California Endangered Species Act
A CESA Incidental Take Permit (ITP) must be obtained from CDFW if the Project has the potential to result in “take” of plants or animals listed under CESA, either during construction or over the life of the Project. Under CESA, “take” means “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” (Fish & G.

Code, § 86). CDFW’s issuance of an ITP is subject to CEQA and to facilitate permit issuance, any Project modifications and mitigation measures must be incorporated into the CEQA document analysis, discussion, and mitigation monitoring and reporting program. If the Project will impact CESA listed species, early consultation is encouraged, as significant modification to the Project and mitigation measures may be required in order to obtain a CESA Permit.

CEQA requires a mandatory finding of significance if a project is likely to substantially impact threatened or endangered species. Pub. Resources Code, §§ 21001, subd. € & 21083; CEQA Guidelines, §§ 15380, 15064 & 15065). In addition, pursuant to CEQA, the Lead Agency cannot approve a project unless all impacts to the environment are avoided or mitigated to less-than-significant levels, or the Lead Agency makes and supports Findings of Overriding Consideration (FOC) for impacts that remain significant despite the implementation of all feasible mitigation. FOC under CEQA, however, does not eliminate the Project proponent’s obligation to comply with the Fish and Game Code.

Lake and Streambed Alteration
CDFW requires an LSA Notification, pursuant to Fish and Game Code section 1600 et seq., for Project activities affecting rivers, lakes or streams and associated riparian habitat. Notification is required for any activity that may substantially divert or obstruct the natural flow; change or use material from the bed, channel, or bank (including associated riparian or wetland resources); or deposit or dispose of material where it DocuSign Envelope ID: 77413C10-952C-45EE-8359-8A56DF9D65D7 Attachment 10

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may pass into a river, lake, or stream. Work within ephemeral streams, drainage ditches, washes, watercourses with a subsurface flow, and floodplains is generally subject to notification requirements. In addition, infrastructure installed beneath such aquatic features, such as through hydraulic directional drilling, is also generally subject to notification requirements. Therefore, any impact to the mainstems, tributaries, or floodplains or associated riparian habitat caused by the proposed Project will likely require an LSA Notification.

Migratory Birds and Raptors
CDFW has authority over actions that may result in the disturbance or destruction of active bird nest sites or the unauthorized take of birds. Fish and Game Code sections protecting birds, their eggs, and nests include section 3503 (regarding unlawful take, possession, or needless destruction of the nests or eggs of any bird), section 3503.5 (regarding the take, possession, or destruction of any birds-of-prey or their nests or eggs), and section 3513 (regarding unlawful take of any migratory nongame bird).

Migratory birds are also protected under the federal Migratory Bird Treaty Act.

Fully Protected Species
Several Fully Protected Species (Fish & G. Code § 3511 and 4700) have the potential to occur within or adjacent to the Project area, including, but not limited to: salt-marsh harvest mouse (Reithrodontomys raviventris), white-tailed kite (Elanus leucurus), golden eagle (Aquila chrysaetos), California least tern (Sternula antillarum browni), and California Ridgway's rail (Rallus obsoletus obsoletus).

Project activities described in the IS/ND should be designed to completely avoid any fully protected species that have the potential to be present within or adjacent to the Project area. Fully protected species may not be taken or possessed at any time and no licenses or permits may be issued for their take except as follows:

Take is for necessary scientific research;
 Efforts to recover a fully protected, endangered, or threatened species, live capture, and relocation of a bird species for the protection of livestock; or  They are a covered species whose conservation and management are provided for in a Natural Community Conservation Plan (Fish & G. Code, §§ 3511, 4700, 5050, & 5515).

Specified types of infrastructure projects may be eligible for an ITP for unavoidable impacts to fully protected species if certain conditions are met (see Fish & G. Code §2081.15).

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CDFW also recommends the IS/ND analyze potential adverse impacts to fully protected species due to habitat modification, loss of foraging habitat, and/or interruption of migratory and breeding behaviors. CDFW recommends that the City include in the analysis how appropriate avoidance, minimization and mitigation measures will reduce indirect impacts to fully protected species. Project proponents should consult with CDFW early in the Project planning process.

PROJECT DESCRIPTION SUMMARY
Proponent: City of Sunnyvale
Objective: The objective of the Project is to achieve the 2030 GHG emissions target for the City of Sunnyvale. Primary Project activities include; the City has developed 19 strategies related clean electricity, building decarbonization, transportation decarbonization and sustainable land use planning, solid waste and water use reductions, community engagement, and climate adaptation.

Location: Sunnyvale, Santa Clara County (County), Citywide Timeframe: The plan will be implemented over the next 21 years.

COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources.

The IS/ND should define the threshold of significance for each impact and describe the criteria used to determine whether the impacts are significant (CEQA Guidelines, § 15064, subd. (f)). The IS/ND relies on General Plan policies and on requirements that subsequent Projects, if necessary, obtain appropriate permits but does not sufficiently describe how these policies will reduce impacts to less-than-significant.

ENVIRONMENTAL SETTING
Sufficient information regarding the environmental setting is necessary to understand any potentially significant impacts on the environment of the proposed Project (CEQA Guidelines, §§15063 & 15360). CDFW recommends that a full list or table is included in the updated Biological Resources Section of the IS/ND that notes species common name, scientific name, state and federal listing status (as applicable), habitat type preference and determination on presence, for all special-status species with the potential to occur within the Project area.

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CDFW recommends the IS/ND provide baseline habitat assessments for special-status plant, fish and wildlife species located and potentially located within the Project area and surrounding lands, including all rare, threatened, and endangered species (CEQA Guidelines, §15380). The IS/ND should describe aquatic habitats, such as wetlands or waters of the U.S. or State, and any sensitive natural communities or riparian habitat occurring on or adjacent to the Project area (for sensitive natural communities see:
https://wildlife.ca.gov/Data/VegCAMP/NaturalCommunities#sensitive%20natural%20co mmunities), and any stream or wetland set back distances the City or County may require.

CDFW recommends that the California Natural Diversity Database (CNDDB), as well as previous studies performed in the area, be consulted to assess the potential presence of sensitive species and habitats. A nine U.S. Geologic Survey (USGS) 7.5-minute quadrangle search is recommended to determine what may occur in the region, larger if the Project area extends past one quad (See Data Use Guidelines on the Department webpage https://wildlife.ca.gov/Data/CNDDB/Maps-and-Data.). Please review the webpage for information on how to access the database to obtain current information on any previously reported sensitive species and habitat, including Significant Natural Areas identified under Chapter 12 of the Fish and Game Code, in the vicinity of the Project. CDFW recommends that CNDDB Field Survey Forms be completed and submitted to CNDDB to document survey results. Online forms can be obtained and submitted at: https://www.wildlife.ca.gov/Data/CNDDB/Submitting-Data.

Please note that CDFW’s CNDDB is not exhaustive in terms of the data it houses, nor is it an absence database. CDFW recommends that it be used as a starting point in gathering information about the potential presence of species within the general area of the Project site. Other sources for identification of species and habitats near or adjacent to the Project area should include, but may not be limited to, State and federal resource agency lists, California Wildlife Habitat Relationship System, California Native Plant Society Inventory, agency contacts, environmental documents for other projects in the vicinity, academics, and professional or scientific organizations. Only with sufficient data and information can the City adequately assess which special-status species are likely to occur in the Project vicinity.

According to Biogeographic Information and Observation System (BIOS) records, the Project site contains positive detections of several special-status species and has the potential to support numerous special-status species and their associated habitat.

Species with potential to occur on-site include but are not limited to those listed in Attachment 1.

I. Project Description and Related Impact Shortcoming
COMMENT 1: Subsequent Project Review, (Biological Resources 4.a. p. 42) DocuSign Envelope ID: 77413C10-952C-45EE-8359-8A56DF9D65D7 Attachment 10

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The IS/ND identifies that “implementation of the following Sunnyvale Playbook Update/ Game Plan 2028 Plays may promote infrastructure development and redevelopment and may result in impacts to species through construction activities.” (4.a. p. 42). It is not clear what level of environmental review future Projects would receive. The IS/ND does not include a checklist for subsequent project review, nor adequate description of how the City’s policies would mitigate any potential impacts of the Project. While the Project has a necessarily broad scope, CDFW recommends providing as much information related to anticipated future activities as possible. CDFW recognizes that, pursuant to CEQA Guidelines section 15152, subdivision (c), if a Lead Agency is using the tiering process in connection with large-scale planning approval, the development of detailed, site-specific information may not be feasible and can be deferred, in many instances, until such time as the Lead Agency prepares a future environmental document. This future environmental document would cover a project of a more limited geographical scale and is appropriate if the deferred information does not prevent adequate identification of significant effects of the planning approval at hand.

The CEQA Guidelines section 15168, subdivision (c)(4) states, “Where the later activities involve site-specific operations, the agency should use a written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were within the scope.” Recommended Mitigation Measure 1: Subsequent Project CEQA Evaluation. The IS/ND should include a procedure or checklist for evaluating subsequent Project impacts on biological resources to determine if the impacts are within the scope of the IS/ND or if an additional environmental document is warranted. Future analysis shall include all special-status species and sensitive habitats including, but not limited to, species considered rare, threatened, or endangered species pursuant to CEQA Guidelines, section 15380. The checklist shall be accompanied by enough relevant information and reasonable inferences to support a “within the scope” of the IS/ND conclusion. For subsequent Project activities that may affect sensitive biological resources, a site-specific analysis shall be prepared by a professional biologist experienced with the applicable species and habitat to provide the necessary supporting information.

II. Environmental Setting and Related Impact Shortcoming Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or U.S. Fish and Wildlife Service (USFWS)?
COMMENT 2: Nesting Bird Surveys, (Biological Resources 4.a. p. 42) DocuSign Envelope ID: 77413C10-952C-45EE-8359-8A56DF9D65D7 Attachment 10

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The draft IS/ND states that the Project has the potential to disturb special-status species and nesting habitat for birds and raptors; however, the draft IS/ND does not state that baseline data will be collected if active nests are discovered.

Recommended Mitigation Measure 2: Nesting Bird Surveys. If Project-related work is scheduled during the nesting season (typically February 15 to August 30 for small bird species such as passerines; January 15 to September 15 for owls; and February 15 to September 15 for other raptors), a professional biologist experienced with the applicable species and habitat shall conduct two surveys for active nests of such birds within 14 days prior to the beginning of Project construction, with a final survey conducted within 48 hours prior to construction. Appropriate minimum survey radii surrounding the work area are typically the following: i) 250 feet for passerines; ii) 500 feet for small raptors such as accipiters; and iii) 1,000 feet for larger raptors such as buteos. Surveys shall be conducted at the appropriate times of day and during appropriate nesting times.

COMMENT 3: Marsh and Shoreline Birds, (Biological Resources 4.a. p. 42) The IS/ND does not state potential impacts to shoreline and marsh birds from the Project. A number of marsh bird species occur along Sunnyvale’s shoreline and throughout the Don Edwards San Francisco Bay National Wildlife Refuge. These include but are not limited to black skimmer (Rynchops niger), California least tern, California black rail, California Ridgway's rail, and western snowy plover (Charadrius nivosus nivosus). The IS/ND includes actions to advance shoreline protection projects and restore and expand salt marshes and natural waterways. Any in-water and shoreline work has the potential to cause the take of state listed marsh and shoreline bird species.

Recommended Mitigation Measure 3: Surveys. CDFW recommends the Project include a measure for marsh bird surveys following the 2017 Site-Specific Protocol for Monitoring Marsh Birds (https://ecos.fws.gov/ServCat/Reference/Profile/68062). CDFW recommends inclusion of avoidance and minimization measures in the Biological Resources Section of the IS/ND to reduce impacts below a level of significance.

COMMENT 4: State Listed Fish Species, (Table 2, item 6.2, page 17) The IS/ND does not include potential impacts to state listed fish species known to be present in the Project area, including steelhead (Oncorhynchus mykiss irideus) - Central California Coast Distinct Population Segment (DPS) and longfin smelt (Spirnichus thaleichthys) along Sunnyvale’s shoreline and throughout the Don Edwards San Francisco Bay National Wildlife Refuge. The IS/ND includes actions to advance shoreline protection projects and restore and expand salt marshes and natural DocuSign Envelope ID: 77413C10-952C-45EE-8359-8A56DF9D65D7 Attachment 10

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waterways. Any in-water work has the potential to cause the take of state listed fish species.

Recommended Mitigation Measure 4: Construction Activities and Work Windows.

The IS/ND should include mitigation measures to avoid potential impacts to aquatic species for construction methods such as pile driving and dredging. In-water construction shall only occur during the CDFW approved work window of June 1 through November 30. A vibratory pile driver shall be used to the maximum extent possible. If an impact hammer is to be considered for construction, the City shall consult with CDFW regarding a CESA ITP for potential impacts to state listed species such as longfin smelt and Chinook salmon (Oncorhynchus tshawytscha). See also Recommended Mitigation Measure 9.

COMMENT 5: Crotch’s bumble bee, (Biological Resources 4.a. p. 42) Crotch’s bumble bee (Bombus crotchii) are candidate species under CESA (CEQA Guidelines, §15380, subds. (c)(1)). The IS/ND does not address whether the proposed Project could result in impacts to Crotch’s bumble bee. Crotch’s bumble bee occurrences have been documented within the vicinity of the Project area and historic observations occur elsewhere in the County (CDFW 2023). The Project location is within the Crotch’s bumble bee range (https://wildlife.ca.gov/Conservation/CESA) and grassland within and adjacent to the Project area may contain potential habitat for Crotch’s bumble bees.

The Project includes strategies such as solar arrays and solar battery storage projects that may occur within ruderal grass and herbaceous vegetation and that may be potential Crotch’s bumble bee nesting and foraging habitat. Potential impacts include direct mortality through crushing or filling of active bee colonies and hibernating bee cavities, reduced reproductive success, loss of suitable breeding and foraging habitats, loss of native vegetation that may support essential foraging habitat.

Recommended Mitigation Measure 5: Habitat Assessment. A habitat assessment shall be conducted by a qualified entomologist knowledgeable with the life history and ecological requirements of Crotch’s bumble bee. The habitat assessment shall include all suitable nesting, overwintering, and foraging habitats within the Project area and surrounding areas. Potential nest habitat (February through October) could include that of other Bombus species such as bare ground, thatched grasses, abandoned rodent burrows or bird nests, brush piles, rock piles, and fallen logs. Overwintering habitat (November through January) could include that of other Bombus species such as soft and disturbed soil or under leaf litter or other debris. The habitat assessment shall be conducted during peak bloom period for floral resources on which Crotch’s bumble bee feed. Further guidance on habitat surveys can be found within Survey Considerations DocuSign Envelope ID: 77413C10-952C-45EE-8359-8A56DF9D65D7 Attachment 10

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for California Endangered Species Act (CESA) Candidate Bumble Bee Species (https://wildlife.ca.gov/Conservation/CESA).

COMMENT 6: Western Burrowing Owl (Biological Resources 4.a. p. 42) Burrowing owl (Athene cunicularia) is designated by CDFW as a California Species of Special Concern (SSC) due to population decline and breeding range retraction. The species has also experienced a severe population decline in the County. The IS/ND notes ruderal infill lots could support burrowing owl but does not discuss potential impacts. Known populations of burrowing owl occur within and adjacent to the Project area, including Moffett Federal Airfield, the Golf Club at Moffett Field, Sunnyvale Baylands County Park, the grasslands along the City of Sunnyvale Water Pollution Control Plant, and other suitable habitat.

The Project includes strategies such as solar arrays and solar battery storage projects that may occur within ruderal grass and herbaceous vegetation that may be potential burrowing owl habitat. The Project also includes shoreline protection strategies which could impact grassland habitat along the shoreline, currently utilized by burrowing owl.

Direct mortality could occur through crushing of adults or young within burrows, loss of nesting burrows, loss of nesting habitat, loss of foraging habitat resulting in reduced nesting success (loss or reduced health or vigor of eggs or young), nest abandonment, and reduced frequency or duration of care for young resulting in reduced health or vigor of young.

Recommended Mitigation Measure 6: Habitat Assessment and Surveys. The IS/ND should include a thorough habitat assessment of potential burrowing owl habitat within and adjacent to the Project area. A professional biologist experienced with burrowing owl and their habitat should conduct a field assessment that includes all areas that could be directly or indirectly impacted by the Project and include data such as vegetation type, vegetation structure and presence of burrows. Specific information on habitat assessment, burrowing owl survey methods, buffer distances and mitigation is provided in the CDFW Staff Report on Burrowing Owl Mitigation, dated March 7, 2012, and available at https://wildlife.ca.gov/Conservation/Survey-Protocols#377281284-birds.

Would the Project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by CDFW or USFWS?
COMMENT 7: Permits for Stream, Wetland, and Other Waters Impacts, Impacts to Sensitive Natural Communities, Riparian Habitat, Wetlands, Lake and Streambed DocuSign Envelope ID: 77413C10-952C-45EE-8359-8A56DF9D65D7 Attachment 10

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Alteration Notification and Clean Water Act compliance (Biological Resources 4.c, p. 43-44)
The IS/ND identifies that future development under the Project may be subject to the Clean Water Act and the Porter-Cologne Water Quality Control Act, but not Fish and Game Code section 1600 et seq. (p. 43). The IS/ND does not provide certainty that such impacts would comply with Fish and Game Code section 1600 et seq., the Porter- Cologne Water Quality Control Act, and the Clean Water Act, as the IS/ND does not include a mitigation measure requiring that development under the Project apply for CDFW, Regional Water Quality Control Board (RWQCB), or U.S. Army Corps of Engineers (USACE) Permits, nor does it contain a mitigation measure requiring compliance with the terms of these permits, if issued.

Development facilitated by the Project may result in impacts to streams and riparian habitats, such as Stevens Creek, Calabazas Creek, and Moffett Channel (p. 44). When riparian habitat is substantially altered, riparian functions become impaired, thereby likely substantially adversely impacting aquatic and terrestrial species. The IS/ND does not provide certainty that impacts to riparian habitats, sensitive natural communities, wetlands, and waters of the State would be reduced to less-than-significant. Without specific mitigation measures containing performance standards CDFW considers impacts to these resources as potentially significant (CEQA Guidelines, §§ 15065, 15380).

To reduce potential impacts to streams, wetlands, and other waters to less-than- significant and comply with Fish and Game Code section 1600 et seq., the Porter- Cologne Water Quality Control Act, and the Clean Water Act, CDFW recommends including the mitigation measure below in the IS/ND.

Recommended Mitigation Measure 7: Stream and Wetland Mitigation and Resource Agency Permits. The Project shall be designed to minimize fill of jurisdictional waters. If impacts to any streams cannot be avoided, then prior to the impacts the Project shall submit an LSA notification to CDFW and comply with the LSA Agreement, if issued. Additionally, if impacts to any streams, wetlands, or other waters cannot be avoided, the Project shall obtain authorization from the RWQCB and USACE pursuant to the Porter-Cologne Water Quality Control Act and Clean Water Act sections 401 and 404, as applicable. Impacts to waters, wetlands, and riparian habitat subject to the permitting authority of CDFW, the RWQCB, or the USACE shall be mitigated by providing restoration at a minimum 3:1 restoration to impact ratio in area for permanent impacts and 1:1 ratio for temporary impacts, unless otherwise approved in writing by CDFW or otherwise required by the RWQCB or USACE. A Habitat Mitigation and Monitoring Plan shall be prepared and implemented for the proposed mitigation. The Project shall obtain written approval of this plan from CDFW, the RWQCB, or the USACE as applicable prior to any disturbance of stream or riparian habitat, wetlands, or other waters.

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Recommended Mitigation Measure 8: LSA Notification and other Resource Agency Permits. The Project shall notify CDFW pursuant to Fish and Game Code section 1600 et seq. using the Environmental Permit Information Management System (EPIMS, see: https://wildlife.ca.gov/Conservation/Environmental-Review/EPIMS) for Project activities affecting lakes or streams, associated riparian or otherwise hydrologically connected habitat, and any connected wetlands, and shall comply with the LSA Agreement, if issued. Projects shall also obtain and comply with applicable permits from the RWQCB and USACE pursuant to the Clean Water Act and Porter- Cologne Water Quality Control Act.

Recommended Mitigation Measure 9: Habitat Restoration and Compensation. The Project shall implement restoration on-site or off-site to mitigate temporary or permanent impacts to sensitive natural communities, riparian habitat, and wetlands at a minimum 1:1 (restore on-site temporary impacts) or 3:1 (permanent impacts) mitigation to impact ratio for acres and linear feet of impacts, or habitat compensation including permanent protection of habitat at the same ratio through a conservation easement and preparing and funding implementation of a long-term management plan, unless otherwise approved in writing by CDFW.

III. Editorial Comments and/or Suggestions
CDFW appreciates the inclusion of strategies to restore and enhance marshes along the shoreline of the City to improve climate resilience and habitat for fish and wildlife. CDFW additionally appreciates the inclusion and proposed implementation of an Urban Forest Management Plan that will result in increased canopy cover within the Project area.

ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e)). Accordingly, please report any special-status species and natural communities detected during Project surveys to the CNDDB. The CNDDB field survey form can be filled out and submitted online at the following link:
https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported to CNDDB can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

ENVIRONMENTAL DOCUMENT FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is DocuSign Envelope ID: 77413C10-952C-45EE-8359-8A56DF9D65D7 Attachment 10

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required in order for the underlying project approval to be operative, vested, and final. (See: Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.).

CONCLUSION
CDFW appreciates the opportunity to comment on the IS/ND to assist the City in identifying and mitigating Project impacts on biological resources.

Questions regarding this letter or further coordination should be directed to Marcus Griswold, Senior Environmental Scientist (Specialist), at (707) 815-6451 or [email protected].

Sincerely,

Erin Chappell
Regional Manager
Bay Delta Region
Attachment 1: Special-Status Species and Commercially/Recreationally Important Species
ec: Office of Planning and Research, State Clearinghouse (SCH No. 2024040387) Craig Weightman, CDFW Bay Delta Region – [email protected] Jason Faridi, CDFW Bay Delta Region – [email protected]

REFERENCES
California Department of Fish and Wildlife (CDFW). 2024. Biogeographic Information and Observation System (BIOS). https://wildlife.ca.gov/Data/BIOS. Accessed April 25, 2024.

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ATTACHMENT 1: Special-Status Species
Species Status
steelhead - central California coast DPS (Oncorhynchus
mykiss irideus) Federally Threatened (FT), State SSC
longfin smelt (Spirinchus thaleichthys) Proposed FT, State Threatened (ST) San Francisco dusky-footed woodrat (Neotoma fuscipes
annectens) SSC
salt-marsh harvest mouse (Reithrodontomys raviventris) Federal Endangered (FE), State Fully Protected (FP)
Bryant's savannah sparrow (Passerculus sandwichensis
alaudinus) SSC
saltmarsh common yellowthroat (Geothlypis trichas sinuosa) SSC burrowing owl (Athene cunicularia) SSC
Alameda song sparrow (Melospiza melodia pusillula) SSC
grasshopper sparrow (Ammodramus savannarum) SSC
tricolored blackbird (Agelaius tricolor) ST, SSC
white-tailed kite (Elanus leucurus) FP
golden eagle (Aquila chrysaetos) FP
northern harrier (Circus hudsonius) SSC
black skimmer (Rynchops niger) SSC
California least tern (Sternula antillarum browni) FE, FP California Ridgway's rail (Rallus obsoletus obsoletus) FE, SE, FP California black rail (Laterallus jamaicensis coturniculus) ST, SSC western snowy plover (Charadrius nivosus nivosus) FT, SSC western mastiff bat (Eumops perotis californicus) SSC
Townsend's big-eared bat (Corynorhinus townsendii) SSC
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western pond turtle (Emys marmorata) Proposed FT, SSC
Crotch's bumble bee (Bombus crotchii) State candidate (SC)

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California Environmental Quality Act (CEQA)
Greenhouse Gas (GHG) Emissions
Thresholds and Guidance
Final
prepared by
City of Sunnyvale
City Manager’s Office
456 W. Olive Avenue
Sunnyvale, CA 94086
prepared with assistance from
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, CA 94612
May 2024
Attachment 10

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Table of Contents

Final i
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Attachment 10

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City of Sunnyvale
CEQA GHG Emissions Thresholds and Guidance

ii
Table of Contents
1 Introduction .................................................................................................................................... 1

1.1 GHG Emissions Analyses Under CEQA ................................................................................ 1

1.2 Qualified GHG Emissions Reduction Plan ........................................................................... 3 2 Climate Action Plan Update/Game Plan 2028 Summary ............................................................... 6

2.1 Communitywide GHG Emissions Inventory ........................................................................ 6

2.2 GHG Emission Reduction Strategy ...................................................................................... 6

2.3 GHG Emissions Forecast...................................................................................................... 8 3 Regulatory and Legal Setting ........................................................................................................13

3.1 Relevant CEQA Guidelines Sections ..................................................................................13

3.2 Relevant State and Regional GHG Reduction Targets ......................................................17

3.3 Relevant GHG Emissions Analysis Case Law .....................................................................19 4 Determining Consistency with the CAP Update/Game Plan 2028 ...............................................22 5 Utilizing Quantitative CEQA GHG Thresholds ...............................................................................26

5.1 Threshold Calculation Methodology .................................................................................26

5.2 GHG Thresholds and Use ..................................................................................................29

5.3 Justification for Thresholds ...............................................................................................31 6 Quantifying GHG Emissions ..........................................................................................................34

6.1 Construction GHG Emissions ............................................................................................34

6.2 Operational GHG Emissions ..............................................................................................35

6.3 Modeling GHG Emissions from Existing Land Use ............................................................38 7 Moving into the Future .................................................................................................................39 Tables
Table 1 CAP Update/Game Plan 2028 Consistency with CEQA Guidelines Section 15183.5(b)(1) for 2030........................................................................................................................................... 5 Table 2 Sunnyvale 1990 and 2019 Communitywide GHG Emissions Levels ................................... 6 Table 3 Sunnyvale GHG Emissions Reductions by 2030 .................................................................. 8 Table 4 Sunnyvale GHG Emissions Forecast Through 2045 ...........................................................10 Table 5 GHG Emissions Forecast for 2030 by Type of Development (MT of CO2e).......................28 Table 6 Sunnyvale Demographic Projections ................................................................................28 Table 7 Sunnyvale 2030 CAP-Adjusted Emissions and Communitywide GHG Thresholds ............29 Table 8 Sunnyvale Locally Applicable Plan/Project CEQA GHG Emissions Thresholds ..................30 Attachment 10

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Table of Contents

Final iii
Figures
Figure 1 Sunnyvale and California GHG Emissions Reduction Targets .......................................2 Figure 2 Sunnyvale GHG Emissions Forecast Through 2045 .......................................................9 Figure 3 Determining Consistency with the Sunnyvale Climate Action Playbook Update/ Game Plan 2028 ...................................................................................................................... 23 Figure 4 Allowable GHG Emissions from Existing and New Development in 2030 ................. 27 Figure 5 Sunnyvale GHG Efficiency Thresholds ........................................................................ 30 Appendices
Appendix A Overview of GHG Emissions and Climate Change Appendix B GHG Threshold Calculations
Appendix C US Green Building Council Building Area per Employee by Business Type Rates

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1 Introduction

1.1 GHG Emissions Analyses Under CEQA
The California Environmental Quality Act (CEQA) requires discretionary plans and projects to undergo an environmental review process, which includes an evaluation of plan- or project-related greenhouse gas (GHG) emissions.1 Section 15183.5 of the CEQA Guidelines establishes a framework for developing a qualified2 GHG reduction plan to cumulatively reduce GHG emissions and allow lead agencies to analyze and mitigate the effects of plan- and project-level GHG emissions. This GHG Emissions Thresholds and Guidance Document is intended to provide methodological guidance and quantitative thresholds of significance for use by City planners, applicants, consultants, agencies, and members of the public in the preparation of GHG emissions analyses under CEQA for plans and projects located within the City of Sunnyvale.

The City of Sunnyvale (City) prepared a CEQA Guidelines Section 15183.5-consistent GHG reduction plan, titled the Climate Action Playbook Update/Game Plan 2028 (CAP Update/Game Plan 2028), with the goal of achieving 56 percent below 1990 GHG emissions levels by 2030 and carbon neutrality by 2045.3 While the City Council, City staff, and community will continue to develop an approach to the longer-term goal of carbon neutrality, the Climate Action Playbook Update/Game Plan 2028 includes specific measures and actions (i.e., plays and moves) to achieve the shorter-term communitywide emissions reduction target of 56 percent below 1990 emissions by 2030, which is consistent with and exceeds California’s goal of reducing GHG emissions to 40 percent below 1990 levels by 2030 (pursuant to Senate Bill [SB] 32). The City has also adopted a goal to achieve carbon neutrality by 2045, aligning with California’s goal of carbon neutrality by 2045 pursuant to Assembly Bill (AB) 1279. See Figure 1 for a representation and comparison of the Sunnyvale and California GHG emissions reduction targets. Therefore, implementation of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 would result in GHG emissions reductions in a manner that exceeds the California 2030 goal.

1 Refer to Appendix A for an overview of GHG emissions and climate change. 2 To be a qualified CAP, a CAP must meet the requirements of CEQA Guidelines Section 15183.5, as further discussed in Section 1.2. 3 Carbon neutrality is defined as net zero carbon emissions, which is achieved either by balancing carbon emissions with carbon removal or by completely eliminating carbon emissions.

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2 Figure 1 Sunnyvale and California GHG Emissions Reduction Targets

Sunnyvale’s 2030 GHG emissions reduction target was developed to provide substantial progress towards achieving the City’s longer-term carbon neutrality target and contribute substantial progress towards meeting the State’s GHG reduction goals identified under SB 32 and AB 1279.

Consistent with this process, the Sunnyvale Climate Action Playbook Update/Game Plan 2028 includes procedures to evaluate Sunnyvale’s GHG emissions in light of the trajectory of the Playbook’s targets to assess its “substantial progress” toward achieving long‐term reduction targets identified in the Sunnyvale Climate Action Playbook Update/Game Plan 2028 and State legislation.

The Sunnyvale Climate Action Playbook Update/Game Plan 2028 also includes commitments and mechanisms to adopt additional policies to achieve further GHG emissions reductions necessary to avoid interference with, and make substantial progress toward, long-term Sunnyvale and California goals. This approach is important, because these targets have been set at levels that achieve California’s fair share of international emissions reduction targets that would stabilize global climate change effects and avoid the adverse environmental consequences of climate change.

To support progress toward Sunnyvale’s longer-term carbon neutrality goal, plans and projects within the City that undergo CEQA review will need to demonstrate consistency with targets in the Sunnyvale Climate Action Playbook Update/Game Plan 2028, which is a qualified GHG Emissions Reduction Plan (consistent with CEQA Guidelines Section 15183.5) upon adoption of its CEQA review document (specifically the Sunnyvale Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds Initial Study-Negative Declaration [IS-ND]), and approval of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 by City Council. Chapter 2, Climate Action Plan Update/Game Plan 2028 Summary, provides an overview of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 and the associated GHG emissions inventories, reduction measures, and forecasts included therein. In addition, Chapter 3, Regulatory and Legal Setting, offers an overview of relevant regulations and case law pertaining to the analysis of GHG emissions consistent with CEQA and the CEQA Guidelines.

Plans and projects that are consistent with the Sunnyvale Climate Action Playbook Update/Game Plan 2028 demographic (i.e., residents and employees) projections and land use assumptions that are based on demographic data contained in Plan Bay Area 2040, would be able to tier from the 602,517
441,846
0 0
-
100,000
200,000
300,000
400,000
500,000
600,000
700,000
State 2030 Target (SB-
32): 40% below 1990
levels
City of Sunnyvale
Target: 56% below
1990 levels
State 2045 Target (AB
1279): Carbon
neutrality
City of Sunnyvale 2045
Target: Carbon
neutrality
GHG Emissions (MT CO2e)
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adopted Sunnyvale Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds IS-ND pursuant to CEQA Guidelines Section 15183.5 with regard to CEQA GHG emissions analysis. To streamline this CEQA GHG emissions analysis process, the City has prepared a CEQA GHG Emissions Analysis Compliance Checklist that can be utilized in plan- and project-level CEQA review documents to determine whether proposed plans and projects are consistent with the Sunnyvale Climate Action Playbook Update/Game Plan 2028 GHG emissions reduction strategy.

Chapter 4, Determining Consistency with Update/Game Plan 2028, includes guidance on how to navigate this consistency determination process.

For plans or projects that are not consistent with the Sunnyvale Climate Action Playbook Update/Game Plan 2028 demographic projections and land use assumptions or are not consistent with the CEQA GHG Emissions Analysis Compliance Checklist, a different methodology and assessment utilizing quantitative thresholds of significance would be necessary to evaluate GHG emissions impacts. Chapter 5, Utilizing Quantitative CEQA GHG Thresholds, includes guidance on how to utilize the quantitative thresholds that were developed for purposes of evaluating the level of significance of GHG emissions impacts.4 Furthermore, Chapter 6, Quantifying GHG Emissions, provides direction regarding how to quantify a plan or project’s GHG emissions for comparison to the applicable threshold of significance.

The Sunnyvale Climate Action Playbook Update/Game Plan 2028 acknowledges that additional actions beyond those identified in the plan will be required to achieve its long-term goal of carbon neutrality by 2045. As a result, the plan provides a mechanism for updating and adopting a new Game Plan every five years (with opportunities to adjust as needed based on Game Plan progress) in order to incorporate new measures and actions (i.e., plays and moves) and technologies that will further move Sunnyvale toward meeting its longer-term carbon neutrality target. Chapter 7, Emission reduction credits that are specific to the proposed plan/project (e.g., use of recycled water, increased density, installation of energy and/or water-efficient appliances, integration of below market rate housing, etc.) should only be included for the proposed plan/project scenario. In addition, care should be taken to identify any emission reduction credits that might be unique to the existing land use designation that would not apply to the proposed plan/project. For example, if the existing land use designation allows for single-family residences and the proposed land use designation would allow for only commercial uses, then the existing scenario should include the emission reduction credit associated with the California 2022 Building Energy Efficiency Standards requirements for PV solar panels on residential uses that are three stories or less whereas the proposed plan/project scenario should not include this credit unless PV solar panels are included as a plan/project design feature.

Moving into the Future, offers further explanation of how CEQA review of plans and projects could be affected by future updates and/or iterations of the Sunnyvale Climate Action Playbook Update/Game Plan 2028.

1.2 Qualified GHG Emissions Reduction Plan
According to CEQA Guidelines Section 15183.5, project-specific environmental documents can tier from, or incorporate by reference, the existing programmatic review of a qualified GHG emissions reduction plan. This process allows for project-level evaluation of GHG emissions through the comparison of a project’s consistency with the GHG emissions reduction strategy included in the

4 In compliance with CEQA Guidelines Section 15064.7(b), this guidance document and the quantitative thresholds contained herein will be presented to the City Council for formal adoption, which includes a public input opportunity.

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4 respective qualified GHG emissions reduction plan. To meet the requirements of CEQA Guidelines Section 15183.5, a qualified GHG emissions reduction plan must include the following:

1. Quantify existing and projected GHG emissions within the plan area;

2. Establish a level, based on substantial evidence, below which the contribution to GHG emissions from activities covered by the plan would not be cumulatively considerable;

3. Identify and analyze sector specific GHG emissions within the plan’s geographic area;

4. Specify measures or a group of measures, including performance standards, that if implemented, would collectively achieve the specified emissions level;

5. Establish a tool or mechanism to monitor progress and to require amendment if the plan is not achieving specified levels; and

6. Be adopted in a public process following environmental review.

Development projects can demonstrate consistency with a qualified GHG emissions reduction plan if they are consistent with the plan’s assumptions regarding future growth projections and consistent with the plan’s GHG emissions reduction measures.5 Projects consistent with the qualified GHG reduction plan, including conformance with performance measures applicable to the project, would not require additional GHG emissions analysis or mitigation under CEQA Guidelines Sections 15064(h) and 15183.5(b)(2). The City of Sunnyvale has developed the CEQA GHG Emissions Analysis Compliance Checklist to assist with determining project consistency with the Sunnyvale Climate Action Playbook Update/Game Plan 2028. The checklist is intended to provide individual projects the opportunity to demonstrate that they are minimizing GHG emissions while ensuring new development achieves its proportion of emissions reductions consistent with the assumptions of the Sunnyvale Climate Action Playbook Update/Game Plan 2028. Project consistency with a GHG emissions reduction plan can also be demonstrated through a quantitative analysis that demostrates the project would not impede (or would facilitate) Sunnyvale’s ability to meet its GHG emissions reduction targets.

Table 1 summarizes the consistency of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 with these requirements for year 2030 (the next California milestone target year for GHG emission reductions). As shown in Table 1, upon adoption of the IS-ND and approval of the plan by City Council, the Sunnyvale Climate Action Playbook Update/Game Plan 2028 will meet the requirements of a qualified GHG emission reduction plan per CEQA Guidelines Section 15183.5(b)(1) for projects with buildout years through 2030.

5 CAPs typically utilize growth projections from the local jurisdiction’s General Plan or applicable Metropolitan Planning Organization’s regional demographic forecast.

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Table 1 CAP Update/Game Plan 2028 Consistency with CEQA Guidelines Section 15183.5(b)(1) for 2030
CEQA Guidelines Section
15183.5(b)(1) Requirement1 Climate Action Plan Update/Game Plan 2028 Consistency Quantify GHG emissions, both
existing and projected over a
specified time period, resulting
from activities within a defined
geographic area.

Consistent. The Sunnyvale CAP Update/Game Plan 2028 includes communitywide GHG emissions inventories for year 2019 and forecasts GHG emissions for years 2030 and 2045.

Establish a level, based on
substantial evidence, below
which the contribution to GHG
emissions from activities
covered by the plan would not
be cumulatively considerable.

Consistent. A key aspect of a qualified GHG emissions reduction plan is substantial evidence that the identified GHG emissions reduction target establishes a threshold where GHG emissions are not cumulatively considerable. The AEP (2016) Beyond Newhall and 2020 white paper identifies this threshold as being a local target that aligns with the State legislative targets. The Sunnyvale Climate Action Playbook Update/Game Plan 2028 establishes a long-term aspirational goal of carbon neutrality by 2045, and as discussed in Section 2.3, GHG Emissions Forecast, implementation of the plan will achieve a 56 percent reduction in 1990 emissions levels by 2030. Therefore, this local target is more stringent than the State target of a 40 percent emission reduction in 1990 levels by 2030.

Identify and analyze the GHG
emissions resulting from
specific actions or categories of
actions anticipated within the
geographic area.

Consistent. The Sunnyvale Climate Action Playbook Update/Game Plan 2028 breaks down its inventories and forecasts into ten sectors (commercial natural gas, residential natural gas, on-road transportation, off-road transportation, solid waste, commercial electricity, residential electricity, wastewater, water, and Caltrain).

Specify measures or a group of
measures, including
performance standards, that
substantial evidence
demonstrates, if implemented
on a project-by-project basis,
would collectively achieve the
specified emissions level.

Consistent. The Sunnyvale Climate Action Playbook Update/Game Plan 2028 specifies measures and actions (i.e., plays and moves) that the City will enact and implement between 2024 and 2030 to meet its 2030 GHG emissions target. As discussed in Section 2.3, GHG Emissions Forecast, implementation of the plan will achieve a 56 percent reduction in 1990 emissions levels by 2030, which is more stringent than the State target of a 40 percent emission reduction in 1990 levels by 2030 and demonstrates substantial progress by 2030 toward achieving Sunnyvale’s longer-term goal of carbon neutrality by 2045.

Establish a mechanism to
monitor the plan’s progress
toward achieving the level and
to require amendment if the
plan is not achieving specified
levels.

Consistent. The Sunnyvale Climate Action Playbook Update/Game Plan 2028 includes a process to complete community GHG emissions inventories every five years. The inventories will allow the City to measure progress towards meeting the Sunnyvale Climate Action Playbook Update/Game Plan 2028 goals. If an inventory indicates that the City is not on track to meet the Sunnyvale Climate Action Playbook Update/Game Plan 2028 GHG emissions goals, additional updates may be required at that time to increase emissions reductions measures and actions (i.e., plays and moves) and maintain the Sunnyvale Climate Action Playbook Update/Game Plan 2028’s status as a CEQA qualified GHG emissions reduction plan.

Be adopted in a public process
following environmental
review.

Consistent. The City prepared an IS-ND for the Sunnyvale Climate Action Playbook Update/Game Plan 2028 that was circulated for public review and comment and adopted prior to approval of the Sunnyvale CAP Update/Game Plan 2028 and CEQA GHG Emissions Thresholds by City Council.

Source: Compiled by Rincon in 2024.

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6 2 Climate Action Plan Update/Game Plan
2028 Summary
The following sections provide an overview of the Sunnyvale Climate Action Playbook Update/Game Plan 2028, including the 2019 communitywide GHG emissions inventory, the communitywide GHG emissions forecast through 2045, and the proposed GHG emission reduction strategy.

2.1 Communitywide GHG Emissions Inventory
The City has completed a communitywide GHG emissions inventory for 2019, which is summarized in Table 2. Table 2 also provides estimated 1990 emissions levels for informational purposes. As shown therein, communitywide GHG emissions declined by approximately 29 percent between 1990 and 2019.

Table 2 Sunnyvale 1990 and 2019 Communitywide GHG Emissions Levels Sector
1990 1
(MT of CO2e)
2019
(MT of CO2e)
Percent Change from 1990 to
2019
Electricity (residential) N/A 282 N/A
Electricity (commercial) N/A 1,298 N/A
Natural Gas (residential) N/A 103,017 N/A
Natural Gas (commercial) N/A 146,412 N/A
On-road Transportation N/A 373,498 N/A
Off-road Transportation N/A 41,425 N/A
Solid Waste N/A 48,506 N/A
Water N/A 23 N/A
Wastewater N/A 802 N/A
Caltrain N/A 1,119 N/A
Total 1,004,194 716,382 -29%
MT of CO2e = metric tons of carbon dioxide equivalents
Note: Numbers are rounded to the nearest ten.
1 1990 GHG emissions were sourced from the Sunnyvale Climate Action Playbook Update/Game Plan 2028.

2.2 GHG Emission Reduction Strategy
To achieve Sunnyvale’s long-term aspirational goal of carbon neutrality by 2045, the Sunnyvale Climate Action Playbook Update/Game Plan 2028 includes a series of Plays and Moves that are intended to reduce communitywide GHG emissions by approximately 56 percent below 1990 levels by 2030, which provides substantial progress toward meeting the City’s longer-term carbon neutrality goal while also exceeding the State’s 2030 target. The Sunnyvale Climate Action Playbook Update/Game Plan 2028 acknowledges that additional Plays and Moves beyond those identified in the plan will be necessary to achieve the long-term aspirational goal of carbon neutrality and, thus, provides a mechanism for updating and adopting a new climate action plan update/game plan every Attachment 10

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Final 7
five years in order to incorporate new plays and moved and technologies that will further Sunnyvale toward meeting its long-term aspirational goal of carbon neutrality.

As part of the Sunnyvale Climate Action Playbook Update process, the City of Sunnyvale has developed a set of strategies to reduce communitywide GHG emissions across various sectors to achieve the Sunnyvale 2030 GHG emission reduction target and make substantial progress towards the Sunnyvale 2045 target. Each strategy is supported by a set of plays and moves that provide measurable GHG emissions reduction that is supported by substantial evidence. The structure of the Strategies, Plays, and Moves are as follows:
▪ Strategies establish approaches to reduce GHG emissions across various sectors that include building energy, transportation, waste/water, and carbon sequestration. Sunnyvale has also developed strategies related to community engagement and climate adaptation. ▪ Plays identify specific goals (i.e., activity data targets by 2030 and 2045) to address GHG emissions in each sector. Plays have measurable targets that would help assess progress towards goals.
▪ Moves define the programs, policies, funding pathways, and other specific actions that the City would implement to address climate change.

The Plays and Moves can be either quantitative or supportive, defined as follows:
▪ Quantitative: Quantitative Plays result in direct and measurable GHG emissions reductions when their Moves, backed by substantial evidence, are implemented. GHG emissions reductions from these Plays and Moves are justified by case studies, scientific articles, calculations, and other third-party substantial evidence that establish the effectiveness of the reduction Moves.

Quantitative Plays can be summed to quantify how the City of Sunnyvale will meet its 2030 GHG emission reduction target and demonstrate progress towards the 2045 target. ▪ Supportive: Supportive Plays and Moves may also be quantifiable and have substantial evidence to support their overall contribution to GHG emission reductions. However, due to one of several factors – including a low GHG emission reduction benefit, indirect GHG emission reduction benefit, or potential for double-counting – they have not been quantified and do not contribute directly to achieving and making progress towards the City’s GHG emission reduction targets. Despite not being quantified, supportive Plays are nevertheless critical to the overall success of the Playbook and provide support so that the quantitative Plays will be successfully implemented.

Table 3 summarizes the GHG emissions reductions that are anticipated to be achieved by 2030 by the identified Plays and Moves in the Sunnyvale Climate Action Playbook Update/Game Plan 2028, in addition to State laws and programs. As shown therein, implementation of State laws and programs as well as the Sunnyvale Climate Action Playbook Update/Game Plan 2028 would reduce 2030 communitywide emissions by approximately 58 percent below 1990 levels, to approximately 419,818 MT of CO2e in 2030.

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8 Table 3 Sunnyvale GHG Emissions Reductions by 2030
Source
Annual GHG Emissions
(MT of CO2e)
1990 Baseline Emissions1 1,004,194
Business-as-Usual 2030 Emissions2 931,298
State Laws/Programs (98,206)
Clean Electricity and Buildings Playbook Update Plays (188,022) Transportation & Sustainable Land Use Playbook Update
Plays
(179,994)
Resource Management Playbook Update Plays (45,258)
Total GHG Emissions Reductions (from Business-as-Usual) (413,274) Remaining 2030 GHG Emissions 419,818
Percent Reduction below 1990 Levels 58%
( ) denotes a negative number; numbers in table may not add to the total exactly due to rounding.

MT CO2e = metric tons of carbon dioxide equivalents
1 See Table 2.
2 See
Table 4.

Source: City of Sunnyvale Playbook Update and GHG Emissions Reductions Technical Evidence

2.3 GHG Emissions Forecast
Figure 2 and Table 4 summarize the communitywide GHG emissions forecast under three scenarios:
1) business-as-usual, 2) implementation of State laws and programs, and 3) implementation of State laws and programs and the Sunnyvale Climate Action Playbook Update/Game Plan 2028. As shown therein, under the business-as-usual scenario, communitywide GHG emissions are forecasted to increase by approximately 75 percent between 2019 and 2045 based on economic and population growth. However, with implementation of State laws and programs, communitywide GHG emissions would increase by approximately 47 percent between 2019 and 2045. Furthermore, full implementation of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 alongside State laws and programs would reduce communitywide GHG emissions by approximately 41 percent below 2019 levels by 2030 and by approximately 42 percent below 2019 levels by 2045.

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Figure 2 Sunnyvale GHG Emissions Forecast Through 2045

2045 Gap
(266,717) MT CO2e
2030 Target Met
(58% below 1990
levels)
441,846 MT CO2e
2045 Target
(85% below 1990
levels)
150,629 MT CO2e
-
200,000
400,000
600,000
800,000
1,000,000
1,200,000
1,400,000
2008 2019 2025 2030 2035 2040 2045
GHG Emissions (MT CO2e)
Reductions Needed to Meet Target 1990 Baseline
Business-as-Usual Forecast Adjusted Forecast
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10 Table 4 Sunnyvale GHG Emissions Forecast Through 2045 Sector
2019
(MT CO2e)
2025
(MT CO2e)
2030
(MT CO2e)
2035
(MT CO2e)
2040
(MT CO2e)
2045
(MT CO2e)
Business-as-Usual GHG Emissions
Residential
Electricity
282 376 440 514 601 703
Nonresidential
Electricity
1,298 1,554 1,677 1,809 1,951 2,105
Residential
Natural Gas
103,017 137,329 160,594 187,800 219,615 256,820 Nonresidential
Natural Gas
146,412 175,333 189,140 204,035 220,103 237,437 On-road
Vehicles
373,498 417,254 457,608 501,864 550,401 603,632 Off-road
Equipment
41,425 47,252 52,510 55,947 59,595 62,011
Waste 48,506 59,767 66,556 74,267 83,032 93,002 Water 23 29 33 37 42 48
Wastewater 802 1,016 1,145 1,291 1,457 1,647 Total 716,382 841,327 931,298 1,029,366 1,138,832 1,259,700 GHG Emissions After Implementation of State Laws/Programs1 Residential
Electricity
282 630 537 147 81 0
Nonresidential
Electricity
1,298 2,562 2,149 580 313 0
Residential
Natural Gas
103,017 134,927 156,564 181,865 211,453 246,054 Nonresidential
Natural Gas
146,412 175,333 189,140 204,035 220,103 237,437 On-road
Vehicles
373,498 367,329 362,876 366,845 382,724 409,817 Off-road
Equipment
41,425 47,252 52,510 55,947 59,595 62,011
Waste 48,506 59,767 66,556 74,267 83,032 93,002 Water 23 23 20 6 3 0
Wastewater 802 1,016 1,145 1,291 1,457 1,647 Caltrain 1,119 1,417 1,596 1,800 2,032 2,296 Total 716,382 790,257 833,092 886,784 960,795 1,052,263 GHG Emissions After Implementation of State Laws/Programs and Playbook Update Residential
Electricity
282 630 (447) (150) (93) 0
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Nonresidential
Electricity
1,298 2,562 (169) (56) (35) 0
Residential
Natural Gas
103,017 88,599 63,467 44,664 35,903 33,221
Nonresidential
Natural Gas
146,412 126,827 97,516 88,448 79,513 74,125
On-road
Vehicles
373,498 306,400 198,635 205,342 217,352 234,741 Off-road
Equipment
41,425 43,202 36,757 39,163 41,717 43,408
Waste 48,506 19,601 21,298 23,226 25,417 27,909 Water 23 23 20 6 3 0
Wastewater 802 1,016 1,145 1,291 1,457 1,647 Caltrain 1,119 1,417 1,596 1,800 2,032 2,296 Total 716,382 590,277 419,818 403,734 403,267 417,347 MT CO2e = metric tons of carbon dioxide equivalents
( ) denotes a negative number; numbers in table may not add to the total exactly due to rounding.

State laws and programs include State vehicle fuel efficiency standards, the Renewable Portfolio Standard, and triennial updates of Title

24. Source: Sunnyvale, City of. 2024. Sunnyvale Through 2045 GHG Forecasts.

At this time, the State has codified a target of reducing emissions to 40 percent below 1990 emissions levels by 2030 (SB 32) and has developed the 2022 Climate Change Scoping Plan to demonstrate how the State will achieve the 2030 target and make substantial progress toward the 2045 goal of carbon neutrality established by AB 1279.

While State and regional regulations related to energy and transportation systems, along with the State’s Cap and Trade program, are designed to be set at limits to achieve most of the GHG emissions reductions needed to achieve the State’s long-term goals, local governments can do their fair share toward meeting the State’s goals by siting and approving projects that accommodate planned population growth and projects that are GHG-efficient. The Association of Environmental Professional (AEP) Climate Change Committee recommends that CEQA GHG analyses evaluate project emissions in light of the trajectory of state climate change legislation and assess their “substantial progress” toward achieving long‐term reduction targets identified in available plans and legislation.

Sunnyvale has adopted a longer-term goal of achieving carbon neutrality by 2045 and has proposed the Sunnyvale Climate Action Playbook Update/Game Plan 2028 as a pathway to make progress toward this goal. Implementation of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 would achieve an approximately 58 percent reduction in communitywide GHG emissions below 1990 levels by 2030. Therefore, the City’s longer-term target of carbon neutrality and the associated Sunnyvale Climate Action Playbook Update/Game Plan 2028 establish a trajectory that provides GHG emissions reductions greater than those required by SB 32 for 2030. Because SB 32 is considered an interim target toward meeting the State long-term goals, implementation of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 would make substantial progress toward meeting the State’s long-term goal. Avoiding interference with, and making substantial progress toward, these long-term State targets is important, because these targets have been set at levels that achieve California’s fair share of international emissions reduction targets that would Attachment 10

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12 stabilize global climate change effects and avoid the adverse environmental consequences described in Appendix A.

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3 Regulatory and Legal Setting
The following regulations, executive orders, and case law pertain to the analysis of GHG emissions consistent with CEQA and the CEQA Guidelines.

3.1 Relevant CEQA Guidelines Sections
Pursuant to the requirements of SB 97, the California Natural Resources Agency has adopted amendments to the CEQA Guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions. The adopted CEQA Guidelines, which were last updated in December 2018, provide general regulatory guidance on the analysis and mitigation of GHG emissions in CEQA documents, while giving lead agencies the discretion to set quantitative or qualitative thresholds for the assessment and mitigation of GHG emissions and climate change impacts.

Based on Appendix G of the CEQA Guidelines, impacts related to GHG emissions generated by a proposed plan/project would be significant if the plan/project would:
▪ Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; and/or
▪ Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs.

The vast majority of individual projects do not generate sufficient GHG emissions to directly influence climate change. However, physical changes caused by a plan/project can contribute incrementally to cumulative effects that are significant, even if individual changes resulting from a plan/project are limited. As discussed in Appendix A, the adverse environmental impacts of cumulative GHG emissions, including sea level rise, increased average temperatures, more drought years, and more large forest fires, are already occurring. As a result, cumulative impacts related to GHG emissions and climate change are significant. Therefore, per CEQA Guidelines Section 15064.4(b), the analysis of GHG emissions under CEQA typically involves an analysis of whether a plan or project’s contribution towards an impact would be cumulatively considerable. “Cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, other current projects, and probable future projects (CEQA Guidelines Section 15064[h][1]).

The following sections of the CEQA Guidelines pertain to the creation of significance thresholds and the analysis of a plan/project’s GHG emissions.

CEQA Guidelines Section 15064(b)
(1) The determination of whether a project may have a significant effect on the environment calls for careful judgment on the part of the public agency involved, based to the extent possible on scientific and factual data. An ironclad definition of significant effect is not always possible because the significance of an activity may vary with the setting. For example, an activity which may not be significant in an urban area may be significant in a rural area.
(2) Thresholds of significance, as defined in Section 15064.7(a), may assist lead agencies in determining whether a project may cause a significant impact. When using a threshold, the Attachment 10

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14 lead agency should briefly explain how compliance with the threshold means that the project’s impacts are less than significant. Compliance with the threshold does not relieve a lead agency of the obligation to consider substantial evidence indicating that the project’s environmental effects may still be significant.6
CEQA Guidelines Section 15064.4
(a) The determination of the significance of GHG emissions calls for a careful judgment by the lead agency consistent with the provisions in section 15064. A lead agency shall make a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate the amount of GHG emissions resulting from a project. A lead agency shall have discretion to determine, in the context of a particular project, whether to (1) Quantify GHG emissions resulting from a project; and/or (2) Rely on a qualitative analysis or performance-based standards. (b) In determining the significance of a project’s GHG emissions, the lead agency should focus its analysis on the reasonably foreseeable incremental contribution of the project’s emissions to the effects of climate change. A project’s incremental contribution may be cumulatively considerable even if it appears relatively small compared to Statewide, national or global emissions. The agency’s analysis should consider a timeframe that is appropriate for the project. The agency’s analysis also must reasonably reflect evolving scientific knowledge and State regulatory schemes. A lead agency should consider the following factors, among others, when determining the significance of impacts from GHG emissions on the environment:
(1) The extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting.
(2) Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.
(3) 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 GHG emissions (see, e.g., section 15183.5[b]). Such requirements must be adopted by the relevant public agency through a public review process and must reduce or mitigate the project’s incremental contribution of GHG emissions. If there is substantial evidence that the possible effects of a particular project are still cumulatively considerable notwithstanding compliance with the adopted regulations or requirements, an EIR must be prepared for the project. In determining the significance of impacts, the lead agency may consider a project’s consistency with the State’s long-term climate goals or strategies, provided that substantial evidence supports the agency’s analysis of how those goals or strategies address the project’s incremental contribution to climate change and its conclusion that the project’s incremental contribution is not cumulatively considerable.
(c) A lead agency may use a model or methodology to estimate GHG emissions resulting from a project. The lead agency has discretion to select the model or methodology it considers most appropriate to enable decision makers to intelligently take into account the project’s incremental contribution to climate change. The lead agency must support its selection of a

6 2022 CEQA Guidelines.

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model or methodology with substantial evidence. The lead agency should explain the limitations of the particular model or methodology selected for use.7 CEQA Guidelines Section 15064.7
(a) A threshold of significance is an identifiable quantitative, qualitative or performance level of a particular environmental effect, non-compliance with which means the effect will normally be determined to be significant by the agency and compliance with which means the effect normally will be determined to be less than significant. (b) Each public agency is encouraged to develop and publish thresholds of significance that the agency uses in the determination of the significance of environmental effects. Thresholds of significance to be adopted for general use as part of the lead agency’s environmental review process must be adopted by ordinance, resolution, rule, or regulation, and developed through a public review process and be supported by substantial evidence. Lead agencies may also use thresholds on a case-by-case basis as provided in Section 15064(b)(2). (c) When adopting or using thresholds of significance, a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence.
(d) Using environmental standards as thresholds of significance promotes consistency in significance determinations and integrates environmental review with other environmental program planning and regulation. Any public agency may adopt or use an environmental standard as a threshold of significance. In adopting or using an environmental standard as a threshold of significance, a public agency shall explain how the particular requirements of that environmental standard reduce project impacts, including cumulative impacts, to a level that is less than significant, and why the environmental standard is relevant to the analysis of the project under consideration. For the purposes of this subdivision, an “environmental standard” is a rule of general application that is adopted by a public agency through a public review process and that is all the following:
(1) a quantitative, qualitative or performance requirement found in an ordinance, resolution, rule, regulation, order, plan or other environmental requirement; (2) adopted for the purpose of environmental protection; (3) addresses the environmental effect caused by the project; and, (4) applies to the project under review.8
CEQA Guidelines Section 15183.5
(a) Lead agencies may analyze and mitigate the significant effects of GHG emissions at a programmatic level, such as in a general plan, a long-range development plan, or a separate plan to reduce GHG emissions. Later project-specific environmental documents may tier from and/or incorporate by reference that existing programmatic review. Project-specific environmental documents may rely on an EIR containing a programmatic analysis of GHG emissions as provided in section 15152 (tiering), 15167 (staged EIRs) 15168 (program EIRs),

7 Ibid.
8 Ibid.

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16 15175–15179.5 (Master EIRs), 15182 (EIRs Prepared for Specific Plans), and 15183 (EIRs Prepared for General Plans, Community Plans, or Zoning). (b) Plans for the Reduction of GHG Emissions. Public agencies may choose to analyze and mitigate significant GHG emissions in a plan for the reduction of GHG emissions or similar document. A plan to reduce GHG emissions may be used in a cumulative impacts analysis as set forth below. Pursuant to sections 15064(h)(3) and 15130(d), a lead agency may determine that a project’s incremental contribution to a cumulative effect is not cumulatively considerable if the project complies with the requirements in a previously adopted plan or mitigation program under specified circumstances. (1) Plan Elements. A plan for the reduction of GHG emissions should:
(A) Quantify GHG emissions, both existing and projected over a specified time period, resulting from activities within a defined geographic area; (B) Establish a level, based on substantial evidence, below which the contribution to GHG emissions from activities covered by the plan would not be cumulatively considerable;
(C) Identify and analyze the GHG emissions resulting from specific actions or categories of actions anticipated within the geographic area;
(D) Specify measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve the specified emissions level; (E) Establish a mechanism to monitor the plan’s progress toward achieving the level and to require amendment if the plan is not achieving specified levels; (F) Be adopted in a public process following environmental review. (2) Use with Later Activities. A plan for the reduction of GHG emissions, once adopted following certification of an EIR or adoption of an environmental document, may be used in the cumulative impacts analysis of later projects. An environmental document that relies on a GHG reduction plan for a cumulative impacts analysis must identify those requirements specified in the plan that apply to the project, and, if those requirements are not otherwise binding and enforceable, incorporate those requirements as mitigation measures applicable to the project. If there is substantial evidence that the effects of a particular project may be cumulatively considerable, notwithstanding the project’s compliance with the specified requirements in the plan for the reduction of GHG emissions, an EIR must be prepared for the project. (c) Special Situations. As provided in Public Resources Code sections 21155.2 and 21159.28, environmental documents for certain residential and mixed use projects, and transit priority projects, as defined in section 21155, that are consistent with the general use designation, density, building intensity, and applicable policies specified for the project area in an applicable sustainable communities strategy or alternative planning strategy need not analyze global warming impacts resulting from cars and light duty trucks. A lead agency should consider whether such projects may result in GHG emissions resulting from other sources, however, consistent with these Guidelines.9

9 Ibid.

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CEQA Guidelines Section 15126.4(c)
Consistent with section 15126.4(a), lead agencies shall consider feasible means, supported by substantial evidence and subject to monitoring or reporting, of mitigating the significant effects of GHG emissions. Measures to mitigate the significant effects of GHG emissions may include, among others:
(1) Measures in an existing plan or mitigation program for the reduction of emissions that are required as part of the lead agency’s decision;
(2) Reductions in emissions resulting from a project through implementation of project features, project design, or other measures, such as those described in Appendix F; (3) Off-site measures, including offsets that are not otherwise required, to mitigate a project’s emissions;
(4) Measures that sequester GHGs;
(5) In the case of the adoption of a plan, such as a general plan, long range development plan, or plans for the reduction of GHG emissions, mitigation may include the identification of specific measures that may be implemented on a project-by-project basis. Mitigation may also include the incorporation of specific measures or policies found in an adopted ordinance or regulation that reduces the cumulative effect of emissions.10

3.2 Relevant State and Regional GHG Reduction Targets
Executive Order S-03-05
On June 1, 2005, the governor issued EO S-03-05, which established a statewide goal of reducing GHG emissions to 1990 levels by 2020 and created the Climate Action Team. The 2020 GHG reduction target contained in EO S-03-05 was later codified by Assembly Bill (AB) 32.

Assembly Bill 32
California’s major initiative for reducing GHG emissions is outlined in AB 32, the “California Global Warming Solutions Act of 2006,” which was signed into law in 2006. AB 32 codifies the State’s goal of reducing Statewide GHG emissions to 1990 levels by 2020 and requires the California Air Resources Board (CARB) to prepare a Scoping Plan that outlines the main State strategies for reducing GHG emissions to meet the 2020 deadline. In addition, AB 32 requires CARB to adopt regulations to require reporting and verification of Statewide GHG emissions. Based on this guidance, CARB approved a 1990 Statewide GHG level and 2020 limit of 427 million metric tons (MMT) of CO2e. The Scoping Plan was approved by CARB on December 11, 2008 and included measures to address GHG emission reduction strategies related to energy efficiency, water use, and recycling and solid waste, among other measures. Many of the GHG reduction measures included in the Scoping Plan (e.g., Low Carbon Fuel Standard, Advanced Clean Car standards, and Cap-and- Trade) have been adopted since approval of the Scoping Plan.11 In May 2014, CARB approved the first update to the AB 32 Scoping Plan. The 2013 Scoping Plan update defined CARB’s climate change priorities for the next five years and set the groundwork to reach post-2020 Statewide goals. The update highlighted California’s progress toward meeting the

10 Ibid.
11 CARB. 2008. Climate Change Scoping Plan. December 2008. https://www.arb.ca.gov/cc/scopingplan/document/adopted_scoping_plan.pdf.

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18 “near-term” 2020 GHG emission reduction goals defined in the original Scoping Plan. It also evaluated how to align the State’s longer-term GHG reduction strategies with other State policy priorities, including those for water, waste, natural resources, clean energy, transportation, and land use. 12
Senate Bill 32
On September 8, 2016, the governor signed SB 32 into law, extending AB 32 by requiring the Statewide reduction of GHG emissions to 40 percent below 1990 levels by 2030 (the other provisions of AB 32 remain unchanged). On December 14, 2017, CARB adopted the 2017 Scoping Plan, which provides a framework for achieving the 2030 target. The 2017 Scoping Plan relies on the continuation and expansion of existing policies and regulations, such as the Cap-and-Trade Program, as well as implementation of recently adopted programs and policies, such as SB 350 and SB 1383.

The 2017 Scoping Plan also puts an increased emphasis on innovation, adoption of existing technology, and strategic investment to support its strategies. As with the 2013 Scoping Plan update, the 2017 Scoping Plan does not provide project-level thresholds for land use development.

Instead, it recommends that local governments adopt policies and locally appropriate quantitative thresholds consistent with Statewide per capita goals of six MT of CO2e by 2030 and two MT of CO2e by 2050. As stated in the 2017 Scoping Plan, these goals may be appropriate for plan-level analyses (city, county, subregional, or regional level), but not for specific individual projects because they include all emissions sectors in the State.13
Senate Bill 375
SB 375, signed in August 2008, enhances the state’s ability to reach AB 32 goals by directing CARB to develop regional GHG emission reduction targets to be achieved from passenger vehicles by 2020 and 2035. SB 375 aligns regional transportation planning efforts, regional GHG reduction targets, and affordable housing allocations. Metropolitan Planning Organizations (MPOs) are required to adopt a Sustainable Communities Strategy (SCS), which allocates land uses in the MPO’s Regional Transportation Plan (RTP). Qualified projects consistent with an approved SCS or Alternative Planning Strategy categorized as “transit priority projects” would receive incentives to streamline CEQA processing.

On March 22, 2018, CARB adopted updated regional targets for reducing GHG emissions from 2005 levels by 2020 and 2035. The Association of Bay Area Governments (ABAG) was assigned targets of a 7 percent reduction in GHGs from transportation sources by 2020 and a 15 percent reduction in GHGs from transportation sources by 2035. ABAG adopted the 2050 RTP (Plan Bay Area 2050) in October 2021, which includes the region’s SCS and meets the requirements of SB 375.14 Assembly Bill 1279
AB 1279, signed in September 2022, builds upon EO B-55-18, which originally established California’s 2045 goal of carbon neutrality and tasked CARB with including a pathway toward the EO B-55-18 carbon neutrality goal in the 2022 Scoping Plan. AB 1279 codified the statewide carbon neutrality goal into a legally binding requirement for California to achieve carbon neutrality no later

12 CARB. 2014. First Update to the Climate Change Scoping Plan. May 15, 2014. https://ww3.arb.ca.gov/cc/scopingplan/2013_update/first_update_climate_change_scoping_plan.pdf. 13 CARB. 2017. 2017 Climate Change Scoping Plan. https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf. 14 Association of Bay Area Governments. October 2021. Plan Bay Area 2050.

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than 2045 and ensure 85 percent15 GHG emissions reduction under that goal. This goal is in addition to the existing statewide GHG emission reduction targets established by SB 375, SB 32, SB 1383, and SB 100.

Senate Bill 1020
Established in 2002 under SB 1078, and accelerated by SB 107 (2006), SB X 1-2 (2011), SB 100 (2018), and SB 1020, California’s Renewable Portfolio Standard (RPS) obligates investor-owned utilities, energy service providers, and community choice aggregators to transition the electricity supply to renewable resources. The RPS requires energy service providers to supply renewable energy as follows: 90 percent of retail sale electricity and 100 percent of electricity procured to serve state agencies by 2035, 95 percent by 2040, and 100 percent by 2045. The CPUC and the CEC are jointly responsible for implementing the program.

Senate Bill 1383
Adopted in September 2016, SB 1383 (Lara, Chapter 395, Statutes of 2016) requires CARB to approve and begin implementing a comprehensive strategy to reduce emissions of short-lived climate pollutants. SB 1383 requires the strategy to achieve the following reduction targets by 2030:
▪ Methane – 40 percent below 2013 levels
▪ Hydrofluorocarbons – 40 percent below 2013 levels
▪ Anthropogenic black carbon – 50 percent below 2013 levels SB 1383 also requires the California Department of Resources Recycling and Recovery (CalRecycle), in consultation with CARB, to adopt regulations that achieve specified targets for reducing organic waste in landfills.

3.3 Relevant GHG Emissions Analysis Case Law
Friends of Oroville v. City of Oroville (Case No. 070448) The Third District Court of Appeal decision in the Friends of Oroville v. City of Oroville case was published on August 19, 2013. This decision evaluated the methodology used to analyze GHG emissions in an Environmental Impact Report (EIR) prepared for a Wal-Mart Supercenter development project that included replacing an existing Wal-Mart store with a Wal-Mart Supercenter in Oroville in Butte County. The EIR used consistency with the AB 32 emissions reduction target as its significance threshold for evaluating the project’s GHG emissions and compared the magnitude of the proposed project’s emissions to statewide 2004 emission levels as part of the analysis. The Court found that EIR applied “a meaningless, relative number to determine insignificant impact” rather than evaluating the project’s emissions in light of the AB 32 emissions reduction target. The Court also found that the EIR “misapplied the [AB] 32 threshold-of-significance standard by [1] failing to calculate the GHG emissions for the existing Wal-Mart and [2] failing to quantitatively or qualitatively ascertain or estimate the effect of the Project’s mitigation measures on GHG emissions.” The Court determined that the EIR could and should have performed these

15 To achieve carbon neutrality, the remaining 15 percent of GHG emissions would be achieved through carbon capture and sequestration efforts.

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20 quantifications to adequately evaluate the project’s GHG emissions using the AB 32 emissions reduction target.

Sierra Club v. County of San Diego (Case No. 37-2018-00043084-CU-TT-CTL) The Fourth District Court of Appeal decision in the Sierra Club v. County of San Diego case was published on October 29, 2014. This decision evaluated the adequacy of the CAP prepared by the County of San Diego to satisfy Mitigation Measure CC-1.2 of the program EIR prepared for its 2011 General Plan. To reduce GHG emissions impacts of the 2011 General Plan to a less-than-significant level, Mitigation Measure CC-1.2 required the preparation of a CAP that would include “more detailed GHG emissions reduction targets and deadlines” and that would “achieve comprehensive and enforceable GHG emissions reduction of 17 percent (totaling 23,572 MT of CO2e) from County operations from 2006 by 2020 and 9 percent reduction (totaling 479,717 MT of CO2e) in community emissions from 2006 by 2020.” The Court found the CAP did not include enforceable and feasible GHG emission reduction measures that would achieve the necessary emissions reductions; therefore, the CAP did not meet the requirements of Mitigation Measure CC-1.2 and would not ensure that the mitigation measure would reduce GHG emissions to a less-than-significant impact.

In addition, the Court found that the County failed to evaluate the environmental impacts of the CAP and its associated thresholds of significance under CEQA.

Center for Biological Diversity v. California Department of Fish and Wildlife (Case No. 217763)
The California Supreme Court’s decision in the Center for Biological Diversity v. California Department of Fish and Wildlife case was published on November 30, 2015. This decision evaluated the methodology used to analyze GHG emissions in an EIR prepared for the Newhall Ranch development project that included approximately 20,885 dwelling units with 58,000 residents on 12,000 acres of undeveloped land in Los Angeles County. The EIR used a business-as-usual approach to evaluate whether the project would be consistent with the AB 32 Scoping Plan. The Court found there was insufficient evidence in the record of that project to explain how a project that reduces its GHG emissions by the same percentage as the business-as-usual reduction identified for the State to meet its Statewide targets supported a conclusion that project-level impacts were below the level of significance.

The California Supreme Court suggested regulatory consistency as a pathway to compliance by stating that a lead agency might assess consistency with the State’s GHG reduction goals by evaluating for compliance with regulations designed to reduce GHG emissions. This approach is consistent with CEQA Guidelines Section 15064.4(b), which provides that a determination of an impact is not cumulatively considerable to the extent to which the project complies with regulations or requirements implementing a Statewide, regional, or local plan to reduce or mitigate GHG emissions. The Court also found that a lead agency may rely on numerical and efficiency-based thresholds of significance for GHG emissions, if supported by substantial evidence.

Golden Door Properties, LLC v. County of San Diego/Sierra Club, LLC v.

County of San Diego (Case No. 072406)
The Fourth District Court of Appeal decision in the Golden Door Properties, LLC v. County of San Diego case (published on September 28, 2018) evaluated the County of San Diego’s 2016 Guidance Document’s GHG efficiency metric, which establishes a generally applicable threshold of significance for proposed projects. The Court held that the County of San Diego is barred from using its 2016 Attachment 10

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Guidance Document’s threshold of significance of 4.9 MT of CO2e per service person per year for GHG analysis. The Court stated that the document violated CEQA because it was not adopted formally by ordinance, rule, resolution, or regulation through a public review process per CEQA Guidelines Section 15064.7(b). The Court also found that the threshold was not supported by substantial evidence that adequately explained how a service population threshold derived from Statewide data could constitute an appropriate GHG metric to be used for all projects in unincorporated San Diego County. Nevertheless, lead agencies may make plan- or project-specific GHG emissions threshold determinations.

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22 4 Determining Consistency with the CAP
Update/Game Plan 2028
As discussed in Chapter 2, Climate Action Plan Update/Game Plan 2028 Summary, upon public adoption of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 IS-ND and approval of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 by City Council, the Sunnyvale Climate Action Playbook Update/Game Plan 2028 will be a qualified GHG emission reduction plan per the requirements of CEQA Guidelines Section 15183.5 for year 2030. Therefore, the Sunnyvale Climate Action Playbook Update/Game Plan 2028 can be utilized to streamline the GHG emissions analysis for plans and projects with buildout years through 2030. Projects that are consistent with the demographic projections and land use assumptions in the Sunnyvale Climate Action Playbook Update/Game Plan 2028 can utilize the Sunnyvale CEQA GHG Emissions Analysis Compliance Checklist to demonstrate consistency with the Sunnyvale Climate Action Playbook Update/Game Plan 2028 GHG emissions reduction strategy, and if consistent, can tier from the environmental review contained in the Sunnyvale Climate Action Playbook Update/Game Plan 2028 IS-ND. In doing so, these projects would result in less-than-significant GHG emissions and not result in a cumulatively considerable GHG emissions impact. The following process (see Figure 3) shows how to demonstrate a plan/project’s consistency with the Sunnyvale Climate Action Playbook Update/Game Plan 2028 GHG emissions reduction strategy and, thereby, tier from the IS-ND for the Sunnyvale Climate Action Playbook Update/Game Plan 2028. This approach is consistent with the recommendations of the AEP Climate Change Committee for tiering from qualified GHG reduction plans that demonstrate substantial progress toward meeting the next milestone Statewide planning reduction target (i.e., a 40 percent reduction below 1990 levels by 2030 as set forth by SB 32).

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Figure 3 Determining Consistency with the Sunnyvale Climate Action Playbook Update/ Game Plan 2028

Step 1: Consistency with Demographic Forecasts and Land Use Assumptions The demographic projections in the Sunnyvale Climate Action Playbook Update/Game Plan 2028 are based on 2040 and 2050 Plan Bay Area projections for Sunnyvale that are based in part on the Sunnyvale General Plan land use designations. If a plan/project is consistent with the existing (2022) General Plan land use and zoning designation(s) of the plan area/project site as identified in the Sunnyvale General Plan Land Use and Transportation Element adopted in June 2022, then the plan/project is consistent with the demographic projections and land use assumptions of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 and can move on to Step 2. In this case, the plan/project’s associated GHG emissions were accounted for in the GHG emissions forecasts included in the Sunnyvale Climate Action Playbook Update/Game Plan 2028 and are within the scope of this plan’s analysis of communitywide GHG emissions. Accordingly, the analysis of the plan/project’s GHG emissions in its CEQA document should include a reference to the plan/project’s consistency with the existing (2022) General Plan land use and zoning designation(s) of the plan area/project site and should explain the aforementioned connection between the existing (2022) General Plan land use and zoning designation(s) and the GHG emissions forecasts in the Sunnyvale Climate Action Playbook Update/Game Plan 2028. Then, proceed to Step 2.

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24 If a plan/project is not consistent with the existing (2022) General Plan land use and zoning designation(s) of the plan area/project site but would result in equivalent or fewer GHG emissions as compared to existing on-site development or the development anticipated for the site under the Sunnyvale existing (2022) General Plan, then the plan/project would still be within the demographic projections and land use assumptions of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 and can move on to Step 2. To provide substantial evidence for this determination, GHG emissions generated under existing conditions/existing (2022) General Plan buildout and the proposed project need to be quantified and included in the CEQA analysis. See Chapter 6, Quantifying GHG Emissions, for guidance on quantifying GHG emissions for existing conditions/existing (2022) General Plan buildout and the proposed plan/project. In this case, the analysis of the plan’s/project’s GHG emissions in its CEQA document should include a quantitative comparison of the proposed plan’s/project’s GHG emissions and GHG emissions generated by existing on-site development or the development anticipated for the site under the Sunnyvale existing (2022) General Plan. The analysis should clearly explain how the plan/project’s emissions are equivalent or less than those generated by existing on-site development or the development anticipated for the site under the Sunnyvale existing (2022) General Plan. Then, proceed to Step 2.

If a plan/project is not consistent with the Sunnyvale existing (2022) General Plan land use and zoning designation(s) of the plan area/project site and would result in either new development of undeveloped land or redevelopment with higher GHG emissions than existing on-site development or than the development anticipated for the site under the Sunnyvale existing (2022) General Plan, the plan/project cannot use the Sunnyvale CEQA GHG Emissions Analysis Compliance Checklist to tier from the adopted IS-ND for the Sunnyvale Climate Action Playbook Update/Game Plan 2028.

Instead, the plan/project’s GHG emissions can be evaluated using the quantitative GHG thresholds described in Chapter 5, Utilizing Quantitative CEQA GHG Thresholds, to evaluate the significance of the plan/project’s GHG emissions. This method can also be utilized for projects with a post-2030 buildout or initial operational year.

Step 2: Consistency with CEQA GHG Emissions Analysis Compliance Checklist The City has prepared the Sunnyvale CEQA GHG Emissions Analysis Compliance Checklist for plans and projects to ensure they are consistent with the strategies, plays, and moves of the Sunnyvale Climate Action Playbook Update/Game Plan 2028. A project applicant can utilize the checklist to show that the plan/project includes all applicable strategies, plays, and moves of the Sunnyvale Climate Action Playbook Update/Game Plan 2028. Projects that use and are consistent with the checklist are not required to quantify reductions from the plays and moves included in the checklist, because the reductions from applicable plays and moves have already been quantified at a programmatic level in the Sunnyvale Climate Action Playbook Update/Game Plan 2028.

If a plan/project is consistent with the applicable strategies, plays, and moves in the Sunnyvale CEQA GHG Emissions Analysis Compliance Checklist, then the plan/project can tier from the programmatic GHG emissions environmental review included in the adopted IS-ND for the Sunnyvale Climate Action Playbook Update/Game Plan 2028 pursuant to CEQA Guidelines Section 15183.5(b)(1).

A plan/project that is consistent with all applicable strategies, plays, and moves of the Sunnyvale CEQA GHG Emissions Analysis Compliance Checklist would result in less-than-significant GHG emissions and would not result in a cumulatively considerable impact related to GHG emissions and climate change. In this case, the analysis of a plan or project’s GHG emissions in its respective CEQA review document should include a summary of the plan/project’s consistency with applicable Attachment 10

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strategies, plays, and moves of the checklist and an explanation with substantial evidence of why any strategies, plays, or moves in the checklist are not applicable to the plan/project.

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26 5 Utilizing Quantitative CEQA GHG Thresholds
As discussed in Chapter 4, Determining Consistency with Update/Game Plan 2028, if a plan/project is not consistent with the Sunnyvale existing (2022) General Plan land use and zoning designation(s) of the plan area/project site, then a plan/project cannot use the Sunnyvale CEQA GHG Emissions Analysis Compliance Checklist to tier from the adopted IS-ND for the Sunnyvale Climate Action Playbook Update/Game Plan 2028. Instead, the significance of a plan/project’s GHG emissions can be evaluated using quantitative GHG thresholds derived from the assumptions of the Sunnyvale Climate Action Playbook Update/Game Plan 2028. If a plan’s/project’s emissions are at or below the applicable threshold, a plan/project can tier from the existing programmatic environmental review contained in the adopted programmatic IS-ND for the Sunnyvale Climate Action Playbook Update/Game Plan 2028 if it has a pre-2030 buildout year. In doing so, such a plans/project would result in less-than-significant GHG emissions and would not result in a cumulatively considerable impact related to GHG emissions and climate change. For a plans/project with post-2030 buildout or initial operational years, emissions at or below the thresholds for 2045 that equate to net zero MT of CO2e per year would be considered less-than-significant, and such a plans/project would not result in a cumulatively considerable GHG emissions impact. The following sections provide an explanation of the methodology used to calculate the thresholds, guidance on how to utilize the thresholds, and justification for use of these thresholds.

5.1 Threshold Calculation Methodology
CEQA Guidelines Section 15064.4 does not establish a specific quantitative threshold of significance for evaluating GHG emissions associated with a proposed plan or project. Lead agencies have the discretion to establish significance thresholds for their respective jurisdictions, and in establishing those thresholds, a lead agency may appropriately look to thresholds developed by other public agencies, or suggested by other experts, as long as the threshold chosen is supported by substantial evidence (CEQA Guidelines Section 15064.7[c]). The following methodology is consistent with guidance provided by the AEP Climate Change Committee in 2016 for establishing GHG emissions efficiency thresholds using the local jurisdictional GHG inventory and demographic forecasts.16 An efficiency threshold is a threshold expressed as a per-person metric (e.g., per resident, per employee, or per service person). Efficiency thresholds are calculated by dividing the allowable GHG emissions inventory in a selected calendar year by the resident, employee, or service population in that year. The efficiency threshold identifies the quantity of GHG emissions that can be generated on a per-person basis without significantly impacting the environment.

Locally appropriate, plan- and project-specific GHG emissions efficiency thresholds were derived from the GHG emissions forecasts calculated for the Sunnyvale Climate Action Playbook Update/Game Plan 2028. These thresholds were created to comply with CEQA and the CEQA Guidelines and interpretive GHG emissions analysis case law, which are summarized in Chapter 3, Regulatory and Legal Setting. The Sunnyvale GHG emissions efficiency thresholds were calculated using the emissions forecasts with all emissions sectors included, because plans and projects would generate vehicle and transit trips, consume energy and water, and produce wastewater and solid

16 AEP. 2016. Final White Paper Beyond 2020 and Newhall: A Field Guide to New CEQA Greenhouse Gas Thresholds and Climate Action Plan Targets for California. https://califaep.org/docs/AEP-2016_Final_White_Paper.pdf.

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waste, thereby generating emissions in all categories. Efficiency thresholds were calculated for year 2030 to provide GHG emissions thresholds for new development in line with the State’s next milestone target, which is for year 2030.

GHG emissions efficiency thresholds would be used during the CEQA review process for new residential, non-residential, and mixed-use plans and projects. Therefore, forecasted GHG emissions in the Sunnyvale Climate Action Playbook Update/Game Plan 2028 were disaggregated into existing development and new development for each threshold year. Furthermore, forecasted GHG emissions for new development were further disaggregated into residential and non-residential development for each threshold year for the purpose of calculating thresholds specific to new residential, non-residential, and mixed-use projects. The results of the disaggregation of the GHG emissions forecast are presented in Figure 4 and Table 5, which summarizes the total amount of GHG emissions expected to be generated by existing, new residential, and new non-residential development for threshold year 2030.

Figure 4 Allowable GHG Emissions from Existing and New Development in 2030

381,205
24,479
14,133
-
50,000
100,000
150,000
200,000
250,000
300,000
350,000
400,000
450,0002030 GHG Emissions (MT CO2e)
Existing New Residential New Nonresidential
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28 Table 5 Allowable GHG Emissions for 2030 by Type of Development (MT of CO2e) Source
2030
Existing
Development
New Development
Residential Non-Residential
Baseline GHG Emissions 716,382 144,174 70,742
State Laws/Programs (65,919) (25,528) (6,759)
Clean Electricity and Buildings Playbook
Update Plays
(111,382) (43,112) (33,528)
Transportation & Sustainable Land Use
Playbook Update Plays
(126,155) (40,797) (13,043)
Resource Management Playbook Update
Plays
(31,720) (10,258) (3,279)
CAP Update/Game Plan 2028-Adjusted
Emissions
381,205 24,479 14,133
( ) denotes a negative value.

See Appendix B for calculations.

Table 6 summarizes the demographic projections for Sunnyvale that were used in calculating GHG efficiency thresholds for year 2030. As shown in Table 6, the numbers of residents, employees, and service persons are all anticipated to increase between 2019 and 2030.

Table 6 Sunnyvale Demographic Projections
Metric 2019 Estimate 2030 Forecast
Net Increase from New
Development
(2019-2030)
Residents 154,252 231,502 77,250
Employees 84,625 109,322 24,697
Service Population1 238,877 340,823 101,946
1 The service population is equal to the residential population plus the number of employees.

Source: Sunnyvale, City of. 2024. Greenhouse Gas Emissions Forecast Report.

Table 7 shows how the remaining emissions for new development after implementation of CAP Update/Game Plan 2028 Plays are used with the demographic projections from Table 6 to create communitywide GHG emissions thresholds for 2030. The resulting GHG thresholds and allowable emissions are specified in Table 7 and Table 8
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Table 7 Sunnyvale 2030 CAP-Adjusted Emissions and Communitywide GHG Thresholds

2030
(New Development)
Residential Non-Residential Mixed-Use
CAP Update/Game Plan 2028-Adjusted 2030
Emissions
(MT of CO2e per year)1
24,479 14,133 38,613
Demographic Metric2 77,250 new residents 24,697 new
employees
101,946 new service
people
GHG Efficiency Threshold
(MT of CO2e per year)

0.32 per resident 0.57 per employee 0.38 per service
person
MT = metric tons; CO2e = carbon dioxide equivalents
1 See Table 5.
2 Demographic estimates are for new plans or projects only and were calculated using the forecasts in Table 6.

5.2 GHG Thresholds and Use
The GHG efficiency thresholds for residential, non-residential, and mixed-use projects built prior to December 31, 2030 are presented in Figure 5 and Table 8. If a plan’s or project’s emissions do not exceed the applicable threshold, then it is considered consistent with the Sunnyvale Climate Action Playbook Update/Game Plan 2028 and its GHG emissions impacts (both project- and cumulative- level) would not result in a cumulatively considerable impact related to GHG emissions and climate change and would, therefore, be less than significant. If a plan’s or project’s emissions exceed the applicable threshold, then mitigation measures must be identified and respective GHG emissions reduction calculations included within the respective CEQA review document in order to reduce plan or project GHG emissions to at or below the applicable threshold level. These thresholds are applicable to the following plan and project types proposed in Sunnyvale:
▪ Residential. Single-family dwellings, multi-family dwellings, boarding house, caretaker quarters, fraternities and sororities, high-occupancy residential uses, continuing care communities, mobile-home parks, or any combination of these uses.
▪ Non-residential. All commercial uses (including office and retail uses), all lodging uses, all public and quasi-public uses, elderly and long-term care, hospice in-patient facilities, family day cares, residential care facilities, supportive and/or transitional housing, sports and entertainment assembly facilities, all industry, manufacturing and processing, and wholesaling uses that are not subject to BAAQMD stationary source permitting or the State’s Cap-and-Trade program, or any combination of these uses.
▪ Mixed-use. A combination of at least one residential and at least one non-residential land use specified above.

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30 Figure 5 Sunnyvale GHG Efficiency Thresholds

Table 8 Sunnyvale Locally Applicable Plan/Project CEQA GHG Emissions Thresholds

2030
(New Development)
Residential Non-Residential Mixed-Use
GHG Efficiency Threshold
(MT of CO2e per year)

0.32 per resident 0.57 per employee 0.38 per service
person
MT = metric tons; CO2e = carbon dioxide equivalents
See Table 7 for the calculation methodology of the thresholds.

0.32 0.57

0.38 -

0.10 0.20

0.30 0.40

0.50 0.60

0.70 New Residential
(per resident)
New Nonresidential
(per job)
New Mixed-Use
(per service person)
GHG Emissions Thresholds (MT CO2e)
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5.3 Justification for Thresholds
Per CEQA Guidelines Section 15064(b)(1), “the determination of whether a project may have a significant effect on the environment calls for careful judgment on the part of the public agency involved, based to the extent possible on scientific and factual data.” In addition, CEQA Guidelines Section 15064(b)(2) states, “When using a threshold, the lead agency should briefly explain how compliance with the threshold means that the project’s impacts are less than significant.” Furthermore, CEQA Guidelines Section 15064.7(b) states “Thresholds of significance to be adopted for general use as part of the lead agency’s environmental review process must be adopted by ordinance, resolution, rule, or regulation, and developed through a public review process and be supported by substantial evidence.” Therefore, the key considerations when developing thresholds of significance are 1) the thresholds’ basis on scientific and factual data; 2) demonstration of how compliance with the thresholds reduces project impacts to a less-than-significant level; 3) support of the thresholds by substantial evidence; and 4) adoption of the thresholds by ordinance, resolution, rule, or regulation, and developed through a public review process. The following subsections address these four key considerations.

Basis of Scientific and Factual Data
As discussed in Section 5.1, Threshold Calculation Methodology, the quantitative thresholds were developed using data from the Sunnyvale 2019 communitywide GHG inventory and the GHG emissions forecasts for year 2030. These inventory and forecasts were developed by the City in compliance with all relevant protocols and guidance documents, including the U.S. Community Protocol for Accounting and Reporting of Greenhouse Gas Emissions, Local Government Operations Protocol, the Global Protocol for Community Scale GHG Emissions, and the Intergovernmental Panel on Climate Change (IPCC) Guidelines for National GHG Inventories. Furthermore, the inventory and forecasts are based on locally appropriate data for Sunnyvale provided by Silicon Valley Clean Energy (SVCE), CARB, Hexagon Transportation Consultants, California Department of Resources Recycling and Recovery (CalRecycle), Sunnyvale Environmental Services Department, and the Sunnyvale Water Pollution Control Plant.17 Therefore, the emission inventory and forecast data underlying the thresholds is both scientific and factual.

As discussed in Section 2.3, GHG Emissions Forecast, implementation of Sunnyvale Climate Action Playbook Update/Game Plan 2028 would achieve a 58 percent reduction in 1990 emissions levels by 2030. Therefore, this local target is more stringent than the State’s target of a 40 percent emission reduction in 1990 levels by 2030 and makes substantial progress toward achieving the State’s long- term goal of carbon neutrality by 2045. The quantitative thresholds are tied directly to the level of GHG emissions anticipated for new development in the Sunnyvale Climate Action Playbook Update/Game Plan 2028 for year 2030. As a result, because the Sunnyvale Climate Action Playbook Update/Game Plan 2028 is consistent with the State’s 2030 GHG emission target, the quantitative thresholds are also consistent with the next State milestone GHG emission reduction target for 2030. The State’s GHG emission reduction targets for 2030 and 2045 are set at the levels scientists say are necessary to meet the Paris Agreement goals to reduce GHG emissions and limit global temperature rise below two degrees Celsius by 2100 in order to avoid dangerous climate change (CARB 2022; AB 1279). Therefore, the Sunnyvale GHG emission reduction targets that inform the Sunnyvale Climate Action Playbook Update/Game Plan 2028 and the associated quantitative thresholds are based on scientific and factual data on the level of emissions reductions necessary to

17 Sunnyvale, City of. 2024. Greenhouse Gas Emissions Forecast Report.

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32 ensure the City does not have a cumulatively considerable contribution to the cumulative impact of climate change.

Reduction of Plan or Project Impacts to a Less-than-Significant Level As shown in Table 5 in Section 5.1, Threshold Calculation Methodology, implementation of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 would reduce annual communitywide GHG emissions by 58 percent by 2030. The quantitative thresholds are tied directly to the level of GHG emissions anticipated for new development in the Sunnyvale Climate Action Playbook Update/Game Plan 2028 for year 2030. Therefore, the thresholds are consistent with the City’s local emission reduction target, which is consistent with the State’s GHG emission reduction targets. As mentioned in the preceding subsection, the State’s GHG emission reduction targets for 2030 and 2045 are set at the levels scientists say are necessary to meet the Paris Agreement goals to reduce GHG emissions and limit global temperature rise below two degrees Celsius by 2100 in order to avoid dangerous climate change (CARB 2022; AB 1279). Therefore, the quantitative thresholds are set at the level necessary to ensure the City does not have a cumulatively considerable contribution to the cumulative impact of climate change. As a result, plans and projects with GHG emissions at or below the quantitative thresholds would also not have a cumulatively considerable contribution to the cumulative impacts of climate change, and plan/project impacts would be less than significant.

Support of Substantial Evidence
Substantial evidence regarding the calculation of the quantitative GHG emissions thresholds is provided in Section 5.1, Threshold Calculation Methodology. The following subsections provide additional evidence of how the GHG emissions thresholds are locally appropriate and plan- or project-specific and how the thresholds distinguish between existing and new development.

Use of Local Data
The quantitative thresholds were developed using the Sunnyvale communitywide GHG emissions forecast for year 2030 and are, thus, specific to the City of Sunnyvale. The thresholds are directly tied to the population and employment growth anticipated by the Sunnyvale 2022 General Plan Land Use and Transportation Element as well as to the City-specific GHG emission reduction strategies, plays, and moves that the City has proposed to reduce communitywide emissions. In addition, the magnitude of local GHG emission reductions achieved by State legislation/policies (i.e., vehicle fuel efficiency standards, the Renewable Portfolio Standard [RPS], and Title 24) was estimated based on City-specific growth and vehicle miles travelled (VMT) forecasts. As a result, these locally appropriate thresholds directly address the concerns raised in the Golden Door Properties, LLC v. County of San Diego/Sierra Club, LLC v. County of San Diego (2018) case, because they are based on local GHG emissions data rather than Statewide GHG emissions data.

Disaggregation of Existing versus New Development
The quantitative thresholds were developed by disaggregating the City’s business-as-usual GHG emissions forecasts for year 2030 into emissions forecasts for existing and new development, which are shown in Table 5 in Section 5.1, Threshold Calculation Methodology. The emissions reductions specific to new development achieved by State legislation/policies and the Sunnyvale Climate Action Playbook Update/Game Plan 2028 were then subtracted from the business-as-usual forecast to determine GHG emissions “caps” for new residential and new non-residential development for year 2030. These “caps” were then divided by the numbers of residents, employees, and service persons Attachment 10

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forecasts for new development to determine efficiency thresholds for residential, non-residential, and mixed-use development, respectively. As a result, these thresholds directly address the concerns raised in the Center for Biological Diversity v. California Department of Fish and Wildlife (2015) case regarding the different rates of GHG emissions reductions anticipated for new development as compared to existing development in order to meet the specified GHG reduction target.

Selection of Sector-Specific Thresholds
The quantitative thresholds are separated into three categories – residential, non-residential, and mixed-use – which are intended to apply to the three main types of development projects in Sunnyvale. These thresholds were calculated by disaggregating the City’s business-as-usual GHG emissions forecasts for new development in year 2030 into emissions forecasts for new residential and new non-residential development, which are shown in Table 5 in Section 5.1, Threshold Calculation Methodology. The emissions reductions specific to new residential and new non- residential development achieved by State legislation/policies and the Sunnyvale Climate Action Playbook Update/Game Plan 2028 were then subtracted from the business-as-usual forecast to determine “caps” of emissions for new residential and new non-residential development for year 2030. These emissions “caps” were then divided by the numbers of residents and employees forecast for new development in year 2030 to determine efficiency thresholds for residential and non-residential projects, respectively. For mixed-use development, the residential and non- residential emissions “caps” were summed, then divided by the service population forecast for new development in year 2030 to determine an efficiency threshold for mixed-use projects. As a result, these project-specific thresholds directly address the concerns raised in the Center for Biological Diversity v. California Department of Fish and Wildlife (2015) case, because they are specific to each development project type.

Adoption via Public Review Process
In compliance with CEQA Guidelines Section 15064.7(b), this guidance document and the quantitative thresholds contained herein will be presented to the City Council for formal adoption through a public review process, which will include an opportunity for public input. The public review process for these City of Sunnyvale CEQA GHG Thresholds and Guidance will specifically occur via public review of and comment on a joint Sunnyvale Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Thresholds IS-ND. The opportunity for public comment will also be available at a public hearing (i.e., City Council meeting) considering adoption of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Thresholds. This process directly addresses the concerns raised in the Golden Door Properties, LLC v. County of San Diego/Sierra Club, LLC v. County of San Diego (2018) case regarding formal adoption of new CEQA thresholds and how lead agencies should afford the opportunity for public review and input prior to adoption and use.

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34 6 Quantifying GHG Emissions
There are a variety of analytical tools available to estimate project-level GHG emissions, including the California Emissions Estimator Model (CalEEMod),18 which is a free, publicly available computer model developed for the California Air Pollution Control Officers Association (CAPCOA) in collaboration with various air quality districts throughout the State. Alternative tools may be used to quantify emissions if they can be substantiated. In general, the most current version of CalEEMod should be used to calculate total emissions for discretionary development projects. The analysis should focus on carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O), because these are the GHGs that most development projects would generate in the largest quantities. Fluorinated gases, such as hydrofluorocarbons, perfluorocarbons, and sulfur hexafluorides, should also be considered for the analysis. Emissions of all GHGs should be converted into their equivalent global warming potential in terms of CO2 (CO2e). Calculations should be based on the current methodologies recommended by CAPCOA and BAAQMD.19, 20

6.1 Construction GHG Emissions
Construction activities emit GHGs primarily though combustion of fuels (mostly diesel) in the engines of off-road construction equipment and in on-road construction vehicles and in the commute vehicles of the construction workers. Smaller amounts of GHGs are emitted indirectly through the energy required for water used for fugitive dust control and lighting for the construction activity. Every phase of the construction process, including demolition, grading, paving, and building, emits GHG emissions in volumes proportional to the quantity and type of construction equipment used. Heavier equipment typically emits more GHGs per hour than lighter equipment because of its engine design and greater fuel consumption.

BAAQMD recommends quantifying and disclosing construction-related GHG emissions for informational purposes.21 CalEEMod generates a default construction schedule and equipment list based on the plan-/project-specific information, including land use type, project size, location, and construction timeline.22 In general, if specific applicant-provided information is unknown, the default construction equipment list and phase lengths are the most appropriate inputs. However, if more detailed site-specific equipment and phase information (i.e., data from the project applicant) is available, the model’s default values can (and should) be overridden.23

18 The most current available version of CalEEMod should be used. As of March 2024, CalEEMod version 2022.1 is the most current version and should be used to quantify project-level emissions. 19 California Air Pollution Control Officers Association. 2008. CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA). January 2008.
20 BAAQMD. 2022. “CEQA Thresholds and Guidelines Update.” https://www.baaqmd.gov/plans-and-climate/california-environmental- quality-act-ceqa/updated-ceqa-guidelines.
21 Ibid
22CAPCOA. 2022. California Emissions Estimator Model User Guide: Version 2022.1. https://www.caleemod.com/documents/user- guide/01_User%20Guide.pdf.
23Ibid.

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6.2 Operational GHG Emissions
CalEEMod estimates operational emissions of CO2, N2O, and CH4 generated by area sources, energy use, vehicle trips (i.e., mobile sources), waste generation, and water use and conveyance.

Operational emissions should be calculated for year 2030, rather than the plan/project buildout year, in order to provide an appropriate comparison of project emissions to the year 2030 threshold.

Area Source Emissions
Area sources include GHG emissions that would occur from the use of landscaping equipment, hearths, and woodstoves that emit GHGs associated with the equipment’s fuel combustion. The landscaping equipment emission values in CalEEMod are derived from CARB’s Small Off-Road Engines Model v1.1 (SORE2020).24 Emission rates for combustion of wood and natural gas for wood stoves and fireplaces are based on those published by the U.S. EPA. Typically, no adjustments to landscaping equipment inputs are necessary. The number of hearths and woodstoves should be adjusted in CalEEMod to reflect the project design.

Energy Use Emissions
GHGs are emitted on-site during the combustion of natural gas for cooking, space and water heating, and decorative uses and off-site during the generation of electricity from fossil fuels in power plants. CalEEMod estimates GHG emissions from energy use by multiplying average rates of residential and non-residential energy consumption by the quantities of residential units and non- residential square footage entered in the land use module to obtain total projected energy use. This value is then multiplied by electricity and natural gas GHG emission factors applicable to the plan/project location and utility provider. Building energy use is typically divided into energy consumed by the built environment and energy consumed by uses that are independent of the building, such as plug-in appliances. Non-building energy use, or “plug-in energy use,” can be further subdivided by specific end-use (refrigeration, cooking, office equipment, etc.). In California, Title 24 governs energy consumed by the built environment, mechanical systems, and some types of fixed lighting.

Electricity emissions are calculated by multiplying the energy use by the carbon intensity of the utility district per kilowatt hour.25 Projects would generally be served by SVCE. The specific energy intensity factors (i.e., the amount of CO2, CH4, and N2O per kilowatt-hour) for the applicable utility should be used in the calculations of GHG emissions.

As of publication of this guidance document, the current iteration of Title 24 includes the 2022 Building Energy Efficiency Standards. In accordance with Section 150.1(b)14 of the 2022 Building Energy Efficiency Standards, all new residential uses three stories or less must install photovoltaic (PV) solar panels that generate an amount of electricity equal to the expected electricity usage. The calculation method contained in Section 150.1(b)14 of the California 2022 Building Energy Efficiency Standards should be utilized to estimate the number of kilowatts of PV solar panels that would be required for a residential project three stories or less. In addition, modeling should account for local regulations pertaining to mandatory solar provisions. Online resources can be used to determine

24Ibid.
25Ibid.

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36 the kilowatt-hours that would be generated per year by the required solar PV system.26 The energy reduction achieved by on-site PV solar panels should be included in CalEEMod. Future updates to Title 24 as they relate to the Building Energy Efficiency Standards should be incorporated into CalEEMod as applicable.

Mobile Source Emissions
CalEEMod quantifies mobile source emissions generated by vehicle trips associated with the proposed plan/project. If available, plan/project-specific trip generation rates or Vehicle Miles Travelled (VMT) data should be input in CalEEMod.

Water and Wastewater Emissions
The amount of water used, and the amount of wastewater generated by a plan/project generate indirect GHG emissions. These emissions are a result of the energy used to supply, convey, and treat water and wastewater. In addition to the indirect GHG emissions associated with energy use, the wastewater treatment process itself can directly emit both CH4 and N2O.

CalEEMod calculates indoor residential water consumption based on per capita daily water use rates from the Residential End Uses of Water published by the Water Research Foundation in 2016. For non-residential land uses, indoor water use comes from the Pacific Institute’s (2003) Waste Not, Want Not: The Potential for Urban Water Conservation in California.27 Outdoor water use is based on the Maximum Applied Water Allowance Method established under the Model Water Efficient Landscape Ordinance. Wastewater generation is based on a reported percentage of total indoor water use.

Future updates to Title 24 as they relate to CALGreen water efficiency requirements should be incorporated into CalEEMod as applicable.

Solid Waste Emissions
The disposal of solid waste produces GHG emissions from the transportation of waste, anaerobic decomposition in landfills, and incineration. To calculate the GHG emissions generated by solid waste disposal, the total volume of solid waste is calculated using waste disposal rates identified by CalRecycle. The methods for quantifying GHG emissions from solid waste are based on the IPCC method, using the degradable organic content of waste. Users should contact the City to obtain the City’s most recent solid rate diversion rate (if available) to be included in the calculation of solid waste GHG emissions.

Plan or Project Design Features
CEQA GHG emissions analysis preparers should use the “Mitigation” tabs to include project design features applicable to the plan/project.28 These features often include increased density, improved destination accessibility, proximity to transit, integration of below market rate housing, unbundling of parking costs, provision of transit subsidies, implementation of alternative work schedules, use of

26 Lane, Catherine. 2023.” How much electricity does a solar panel produce?” Last updated: June 13, 2023. https://www.solarpowerrocks.com/solar-basics/how-much-electricity-does-a-solar-panel-produce/. 27CAPCOA. 2022. California Emissions Estimator Model User Guide: Version 2022.1. Prepared by ICF in collaboration with Sacramento Metropolitan Air Quality Management District, Fehr & Peers, STI, and Ramboll. http://www.aqmd.gov/caleemod/user's-guide. 28 “Mitigation” is a term of art for the modeling input and is not equivalent to mitigation measures that may apply to the CEQA impact analysis.

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energy- and/or water-efficient appliances, use of reclaimed and/or grey water, and installation of water-efficient irrigation system. Such preparers should also consider the applicability of these features to the plan/project and review the CAPCOA Quantifying Greenhouse Gas Mitigation Measures (2010) publication to ensure that the chosen features are relevant and feasible in light of the plan/project.29
Residents, Employees, and Service Populations
The quantitative thresholds presented in Chapter 5, Utilizing Quantitative CEQA GHG Thresholds, are expressed in terms of per resident for residential projects, per employee for non-residential projects, and per service person for mixed-use projects. Estimates of the resident, employee, or service population for a plan/project should be based on substantial evidence. Data provided by the applicant as well as the following resources may be utilized in estimating resident and employee populations:
▪ Persons per Household. The California Department of Finance website (https://www.dof.ca.gov/Forecasting/Demographics/Estimates/e-5/) should be referenced for the most recent estimate of persons per household in Sunnyvale. This estimate can be multiplied by the number of proposed residential units to estimate a plan/project’s resident population.
▪ Proposed Number of Beds. For projects such as group homes, assisted living facilities, nursing homes, or similar uses, the number of beds can be used to determine the resident population. ▪ United States Green Building Council. The United States Green Building Council has published a summary of building area per employee by business type. These rates, which are expressed in terms of square feet per employee, can be utilized to estimate the number of employees a plan/project would require. This document is included as Appendix G.

29 CAPCOA. 2010. Quantifying Greenhouse Gas Mitigation Measures. August 2010. http://www.capcoa.org/wp- content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf.

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38 6.3 Modeling GHG Emissions from Existing Land Use
For a plan/project that would result in a change in the plan area/project’s site General Plan land use designation, emissions anticipated for the Sunnyvale existing (2022) General Plan land use designation must be calculated in conjunction with emissions for the proposed plan/project to demonstrate whether the plan/project would be more or less GHG-intensive than development anticipated for the existing (2022) General Plan land use designation for the site. In this case, GHG emissions should be reported for both the existing and proposed scenarios. If there is a land use designation that allows multiple uses, the project could model the most intensive permitted use from the GHG perspective and compare the project to that as the baseline.

Emissions anticipated for the existing land use should be quantified using the methods described in Section 6.1, Construction Emissions, and Section 6.2, Operational Emissions with consistent assumptions between the two scenarios as applicable. Any emission reduction credits applied to the proposed plan/project scenario that are related to State legislation/policies (e.g., the RPS, vehicle standards, Title 24) or the plan area/project site location (e.g., proximity to transit, destination accessibility, etc.) should also be applied to the existing scenario.

Emission reduction credits that are specific to the proposed plan/project (e.g., use of recycled water, increased density, installation of energy and/or water-efficient appliances, integration of below market rate housing, etc.) should only be included for the proposed plan/project scenario. In addition, care should be taken to identify any emission reduction credits that might be unique to the existing land use designation that would not apply to the proposed plan/project. For example, if the existing land use designation allows for single-family residences and the proposed land use designation would allow for only commercial uses, then the existing scenario should include the emission reduction credit associated with the California 2022 Building Energy Efficiency Standards requirements for PV solar panels on residential uses that are three stories or less whereas the proposed plan/project scenario should not include this credit unless PV solar panels are included as a plan/project design feature.

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Final 39
7 Moving into the Future
Full implementation of the Sunnyvale Climate Action Playbook Update/Game Plan 2028 would reduce communitywide GHG emissions by approximately 58 percent below 1990 levels by 2030 that in turn would leave a gap of approximately 266,717 MT of CO2e per year in 2045 that would need to be addressed to achieve carbon neutrality. This gap represents emissions that could be addressed by laws, regulations, policies, programs, and ordinances set forth by the federal and State governments, regional agencies, and local partners. The gap also represents the uncertainty that the City of Sunnyvale faces in taking a leadership role in addressing a challenge that has not been previously solved.

Sunnyvale is committed to embracing that uncertainty, striving toward constant learning, engaging in systemic change using the tools and actions that local governments are uniquely suited to carry out, and positioning itself to take full advantage of future innovations, technologies, policies, and legislation that may be undertaken at the State and federal level. Technological innovation, clean- tech innovation, and changes to climate-related policy and regulation occur rapidly. Several of the State’s most successful environmental policy initiatives, including the RPS, also had a gap between what was known at the time of adoption and eventual successful implementation. By committing to the target of carbon neutrality by 2045, Sunnyvale intends to catalyze innovation, invite resources from funding sources and partners, and provide climate leadership.

The Sunnyvale Climate Action Playbook Update/Game Plan 2028 acknowledges that additional actions beyond those identified in the plan would be necessary to achieve carbon neutrality and, thus, provides a mechanism for updating and adopting a new climate action plan every five years in order to incorporate new measures and innovative technologies that will further Sunnyvale toward meeting its goal of carbon neutrality. As the CAP Update/Game Plan is updated, the associated CEQA GHG Emissions Analysis Compliance Checklist will also be updated as needed to incorporate new strategies, plays, and/or moves that discretionary development projects would need to incorporate, as applicable, to demonstrate consistency with the latest CAP Update/Game Plan. At the time at which the City identifies strategies, plays, and/or moves to achieve its carbon neutrality goal in totality, the City will adopt those collective strategies, plays, and moves in a public process following CEQA review, at which time that updated CAP Update/Game Plan would become a qualified GHG emission reduction plan for projects with post-2030 buildout years. However, the quantitative thresholds included in this guidance document will not need to be updated, because residential, non-residential, and mixed-use projects with post-2030 buildout years will still need to achieve GHG emissions equivalent to zero MT of CO2e per year to demonstrate consistency with the Sunnyvale Climate Action Playbook Update/Game Plan.

Finally, if future amendments or updates of the Sunnyvale General Plan Land Use and Transportation Element occur, then such amendments or updates will be incorporated into future updates of the Sunnyvale Climate Action Playbook Update/Game Plan to ensure that project planners and applicants can continue to utilize the CEQA GHG emissions analysis streamlining process detailed in this document, given that this process is partly dependent on a plan’s/project’s consistency with the demographic projections and land use assumptions of the Sunnyvale General Plan.

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Appendix A
Overview of GHG Emissions and Climate Change

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Overview of GHG Emissions and Climate
Change
Climate Change and Greenhouse Gases
Climate change is the observed increase in the average temperature of Earth’s atmosphere and oceans along with other substantial changes in climate (such as wind patterns, precipitation, and storms) over an extended period. The term “climate change” is often used interchangeably with the term “global warming,” but “climate change” is preferred to “global warming” because it helps convey other changes in addition to rising temperatures. The baseline against which these changes are measured originates from historical records identifying temperature changes that have occurred in the past, such as during previous ice ages. The global climate changes continuously, as evidenced by repeated episodes of substantial warming and cooling documented in the geologic record. The rate of change has typically been incremental, with warming or cooling trends occurring over the course of thousands of years. The past 10,000 years have been marked by a period of incremental warming, as glaciers have steadily retreated across the globe. However, scientists have observed substantial acceleration in the rate of warming during the past 150 years. The United Nations Intergovernmental Panel on Climate Change (IPCC) expressed that the rise and continued growth of atmospheric CO2 concentrations is unequivocally due to human activities in the IPCC’s Sixth Assessment Report from 2021. Human influence has warmed the atmosphere, ocean, and land, which has led the climate to warm at an unprecedented rate in the last 2,000 years. It is estimated that between the period of 1850 through 2019, that a total of 2,390 gigatonnes of anthropogenic CO2 was emitted. It is likely that anthropogenic activities have increased the global surface temperature by approximately 1.07 degrees Celsius between the years 2010 through 2019.30 Furthermore, since the late 1700s, estimated concentrations of carbon dioxide (CO2), methane (CH4), nitrous oxides (N2O) in the atmosphere have increased by over 43 percent, 156 percent, and 17 percent, respectively, primarily due to human activity.31 Emissions resulting from human activities are thereby contributing to an average increase in Earth’s temperature.

Gases that absorb and re-emit infrared radiation in the atmosphere are called GHGs. The gases widely seen as the principal contributors to human-induced climate change include CO2, CH4, N2O, fluorinated gases such as hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). Water vapor is excluded from the list of GHGs because it is short-lived in the atmosphere, and natural processes, such as oceanic evaporation, largely determine its atmospheric concentrations.

GHGs are emitted by natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities from human activities. Emissions of CO2 are usually by-products of fossil fuel combustion, and CH4 results from off-gassing associated with agricultural practices and

30 Intergovernmental Panel on Climate Change (IPCC). 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte, V., P. Zhai, A. Pirani, S. L.

Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L. Goldfarb, M. I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T. K. Maycock, T.

Waterfield, O. Yelekçi, R. Yu and B. Zhou (eds.)] Cambridge University Press. https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf 31 United States Environmental Protection Agency (U.S. EPA). 2021. Climate Change Indicators: Atmospheric Concentrations of Greenhouse Gases. Last updated April 2021. https://www.epa.gov/climate-indicators/climate-change-indicators-atmospheric- concentrations-greenhouse-gases
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landfills. Human-made GHGs, many of which have greater heat-absorption potential than CO2, include fluorinated gases and SF6.32
Different types of GHGs have varying global warming potentials (GWP). The GWP of a GHG is the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a common reference gas (CO2) is used to relate the amount of heat absorbed to the amount of the gas emitted, referred to as “carbon dioxide equivalent” (CO2e), which is the amount of GHG emitted multiplied by its GWP. Carbon dioxide has a 100-year GWP of one. By contrast, CH4 has a GWP of 30, meaning its global warming effect is 30 times greater than CO2 on a molecule per molecule basis.33,34 The accumulation of GHGs in the atmosphere regulates the earth’s temperature. Without the natural heat-trapping effect of GHGs, the earth’s surface would be about 33 degrees Celsius (°C) cooler.35 However, since 1750, estimated concentrations of CO2, CH4, and N2O in the atmosphere have increased by 36 percent, 148 percent, and 18 percent, respectively, primarily due to human activity.36 GHG emissions from human activities, particularly the consumption of fossil fuels for electricity production and transportation, are believed to have elevated the concentration of these gases in the atmosphere beyond the level of concentrations that occur naturally.

Greenhouse Gas Emissions Inventories
Global Emissions Inventory
In 2015, worldwide anthropogenic GHG emissions totaled 47,000 MMT of CO2e, which is a 43 percent increase from 1990 GHG levels. The largest source of GHG emissions were energy production and use (includes fuels used by vehicles and buildings), which accounted for 75 percent of the global GHG emissions. Agriculture uses and industrial processes contributed 12 percent and six percent, respectively. Waste sources contributed three percent. These sources account for approximately 96 percent.37

32 U.S. EPA. 2021. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2019. April 2021. https://www.epa.gov/system/files/documents/2022-02/us-ghg-inventory-2022-main-text.pdf 33 The IPCC’s Sixth Assessment Report from 2021 determined that methane has a GWP of 30. However, the 2017 Climate Change Scoping Plan published by the California Air Resources Board uses a GWP of 25 for methane, consistent with the Intergovernmental Panel on Climate Change’s Fourth Assessment Report from 2007. Therefore, this analysis utilizes a GWP of 25. 34 IPCC. 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte, V., P. Zhai, A. Pirani, S. L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L.

Goldfarb, M. I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T. K. Maycock, T. Waterfield, O. Yelekçi, R. Yu and B. Zhou (eds.)] Cambridge University Press. https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf 35 World Meteorological Organization. 2020. “Greenhouse Gases.” https://public.wmo.int/en/our-mandate/focus- areas/environment/greenhouse%20gases
36 Forster, P., V. Ramaswamy, P. Artaxo, T. Berntsen, R. Betts, D.W. Fahey, J. Haywood, J. Lean, D.C. Lowe, G. Myhre, J.

Nganga, R. Prinn, G. Raga, M. Schulz and R. Van Dorland. 2007. Changes in Atmospheric Constituents and in Radiative Forcing. Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M.Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA. https://www.ipcc.ch/site/assets/uploads/2018/02/ar4-wg1-chapter2-1.pdf 37 U.S. EPA. 2023. Climate Change Indicators: Global Greenhouse Gas Emissions. Available at: https://www.epa.gov/climate- indicators/climate-change-indicators-global-greenhouse-gas-emissions Attachment 10

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United States Emissions Inventory
United States GHG emissions were 6,347.7 MMT of CO2e in 2021 (or 5,593.5 MMT CO2e after accounting for sequestration), a 6.8 percent increase from 2020 emissions. The increase from 2020 to 2021 was driven by an increase in CO2 emissions from fossil fuel combustion which increased 7 percent relative to previous years and is primarily due to the economic rebounding after the COVID- 19 pandemic. In 2020, the energy sector (including transportation) accounted for 81 percent of nationwide GHG emissions while agriculture, industrial and waste accounted for approximately 10 percent, 6 percent, and 3 percent respectively.38
California Emissions Inventory
Based on a review of the CARB California Greenhouse Gas Inventory for the years between 2000- 2020, California produced 369.2 MMT of CO2e in 2020, which is 35.3 MMT of CO2e lower than 2019 levels. The 2019 to 2020 decrease in emissions is likely due in large part to the impacts of the COVID-19 pandemic. The major source of GHG emissions in California is the transportation sector, which comprises 37 percent of the state’s total GHG emissions. The industrial sector is the second largest source, comprising 20 percent of the state’s GHG emissions while electric power accounts for approximately 16 percent. The magnitude of California’s total GHG emissions is due in part to its large size and large population compared to other states. However, a factor that reduces California’s per capita fuel use and GHG emissions as compared to other states is its relatively mild climate. In 2016, the state of California achieved its 2020 GHG emission reduction target of reducing emissions to 1990 levels as emissions fell below 431 MMT of CO2e.39 The annual 2030 statewide target emissions level is 260 MMT of CO2e.40
Potential Effects of Climate Change
Globally, climate change has the potential to affect numerous environmental resources through potential impacts related to future air temperatures and precipitation patterns. Scientific modeling predicts that continued GHG emissions at or above current rates would induce more extreme climate changes during the 21st century than were observed during the 20th century. Long-term trends have found that each of the past four decades has been warmer than all the previous decades in the instrumental record and the decade from 2011 through 2020 has been the warmest.

The observed global mean surface temperature (GMST) for the decade from 2011 to 2020 was approximately 1.09°C (0.95°C to 1.20°C) higher than the average GMST over the period from 1850 to 1900. Due to past and current activities, anthropogenic GHG emissions are increasing global mean surface temperature at a rate of 0.2°C per decade. In addition to these findings, the latest IPCC report states that “human-induced climate change is already affecting many weather and climate extremes in every region across the globe.”41 These climate change impacts include climate change

38 U.S. EPA. 2023. Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2021. Available at:
https://www.epa.gov/system/files/documents/2023-04/US-GHG-Inventory-2023-Main-Text.pdf 39 CARB. 2022. 2022 Scoping Plan for Achieving Carbon Neutrality. Available at: https://ww2.arb.ca.gov/sites/default/files/2023- 04/2022-sp.pdf
40 CARB. 2017. California’s 2017 Climate Change Scoping Plan. Available at:
https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017.pdf 41 IPCC. 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte, V., P. Zhai, A. Pirani, S. L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L.

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sea level rise, increased weather extremes, and substantial ice loss in the Arctic over the past three decades.

According to California’s Fourth Climate Change Assessment, statewide temperatures from 1986 to 2016 were approximately 0.6 to 1.1°C higher than those recorded from 1901 to 1960. Potential impacts of climate change in California may include reduced water supply from snowpack, sea level rise, more extreme heat days per year, more large forest fires, and more drought years.42 In addition to statewide projections, California’s Fourth Climate Change Assessment includes regional reports that summarize climate impacts and adaptation solutions for nine regions of the State and regionally-specific climate change case studies.43 However, while there is growing scientific consensus about the possible effects of climate change at a global and statewide level, current scientific modeling tools are unable to predict what local impacts may occur with a similar degree of accuracy. A summary follows of some of the potential effects that could be experienced in California as a result of climate change.

Hydrology and Sea Level Rise
Climate change could affect the intensity and frequency of storms and flooding.44 Furthermore, climate change could induce substantial sea level rise in the coming century. Rising sea level increases the likelihood of and risk from flooding. The rate of increase of global mean sea levels between 1993 to 2020, observed by satellites, is approximately 3.3 millimeters per year, double the twentieth century trend of 1.6 millimeters per year.45,46 Global mean sea levels in 2013 were about

0.23 meter higher than those of 1880.47 Sea levels are rising faster now than in the previous two millennia, and the rise will probably accelerate, even with robust GHG emission control measures.

The most recent IPCC report predicts a mean sea level rise of 11 to 21.5 inches by 2100 under the lowest emissions scenario and a rise of 25 to 40 inches by 2100 under the very high emissions scenario.48
A rise in sea levels could erode 31 to 67 percent of California beaches and cause flooding of approximately 370 miles of coastal highways during 100-year storm events. This would also jeopardize California’s water supply due to saltwater intrusion and induce groundwater flooding and/or exposure of buried infrastructure.49 Furthermore, increased storm intensity and frequency could affect the ability of flood-control facilities, including levees, to handle storm events.

42 California, State of. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. August 27, 2018. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide_Reports-SUM-CCCA4-2018-013_Statewide_Summary_Report_ADA.pdf 43 Ibid.
44 Ibid.
45 World Meteorological Organization. 2013. A summary of current and climate change findings and figures: a WMO information note.

March 2013. https://library.wmo.int/opac/index.php?lvl=notice_display&id=15892#.Wt9-Z8gvzIU 46 National Aeronautics and Space Administration. 2020. “Global Climate Change – Vital Signs of the Planet – Sea Level.” https://climate.nasa.gov/vital-signs/sea-level/
47 Ibid.
48 IPCC. 2021. Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Masson-Delmotte, V., P. Zhai, A. Pirani, S. L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L.

Goldfarb, M. I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T. K. Maycock, T. Waterfield, O. Yelekçi, R. Yu and B. Zhou (eds.)] Cambridge University Press. https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_Full_Report.pdf 49 California, State of. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. August 27, 2018. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide_Reports-SUM-CCCA4-2018-013_Statewide_Summary_Report_ADA.pdf Attachment 10

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Air Quality
Scientists project that the annual average maximum daily temperatures in California could rise by

2.4 to 3.2°C in the next 50 years and by 3.1 to 4.9°C in the next century.50 Higher temperatures are conducive to air pollution formation, and rising temperatures could therefore result in worsened air quality in California. As a result, climate change may increase the concentration of ground-level ozone, but the magnitude of the effect, and therefore its indirect effects, are uncertain. In addition, as temperatures have increased in recent years, the area burned by wildfires throughout the State has increased, and wildfires have occurred at higher elevations in the Sierra Nevada Mountains.51 If higher temperatures continue to be accompanied by an increase in the incidence and extent of large wildfires, air quality could worsen. Severe heat accompanied by drier conditions and poor air quality could increase the number of heat-related deaths, illnesses, and asthma attacks throughout the State. However, if higher temperatures are accompanied by wetter, rather than drier conditions, the rains could tend to temporarily clear the air of particulate pollution, which would effectively reduce the number of large wildfires and thereby ameliorate the pollution associated with them.52 Water Supply
Analysis of paleoclimatic data (such as tree-ring reconstructions of stream flow and precipitation) indicates a history of naturally and widely varying hydrologic conditions in California and the west, including a pattern of recurring and extended droughts. Uncertainty remains with respect to the overall impact of climate change on future precipitation trends and water supplies in California.

Year-to-year variability in statewide precipitation levels has increased since 1980, meaning that wet and dry precipitation extremes have become more common.53 This uncertainty regarding future precipitation trends complicates the analysis of future water demand, especially where the relationship between climate change and its potential effect on water demand is not well understood. The average early spring snowpack in the western U.S., including the Sierra Nevada Mountains, decreased by about 10 percent during the last century. During the same period, sea level rose over 0.15 meter along the central and southern California coasts.54 The Sierra snowpack provides the majority of California's water supply as snow that accumulates during wet winters is released slowly during the dry months of spring and summer. A warmer climate is predicted to reduce the fraction of precipitation that falls as snow and the amount of snowfall at lower elevations, thereby reducing the total snowpack.55 Projections indicate that average spring snowpack in the Sierra Nevada and other mountain catchments in central and northern California will decline by approximately 66 percent from its historical average by 2050.56

50 Ibid.
51 Ibid.
52 California Natural Resources Agency. 2009. 2009 California Climate Adaptation Strategy. March 2009. http://resources.ca.gov/docs/climate/Statewide_Adaptation_Strategy.pdf 53 California Department of Water Resources. 2018. Indicators of Climate Change in California. May 2018. https://oehha.ca.gov/media/downloads/climate-change/report/2018caindicatorsreportmay2018.pdf 54 California, State of. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. August 27, 2018. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide_Reports-SUM-CCCA4-2018-013_Statewide_Summary_Report_ADA.pdf 55 Ibid.
56 Ibid.

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Agriculture
California has an over $51 billion annual agricultural industry that produces over a third of the country’s vegetables and three-quarters of the country’s fruits and nuts.57 Higher CO2 levels can stimulate plant production and increase plant water-use efficiency. However, if temperatures rise and drier conditions prevail, certain regions of agricultural production could experience water shortages of up to 16 percent, which would increase water demand as hotter conditions lead to the loss of soil moisture. In addition, crop yield could be threatened by water-induced stress and extreme heat waves, and plants may be susceptible to new and changing pest and disease outbreaks (California Natural Resource Agency 2019). Temperature increases could also change the time of year certain crops, such as wine grapes, bloom or ripen, and thereby affect their quality.58 Ecosystems and Wildlife
Climate change and the potential resultant changes in weather patterns could have ecological effects on the global and local scales. Soil moisture is likely to decline in many regions as a result of higher temperatures, and intense rainstorms are likely to become more frequent. Rising temperatures could have four major impacts on plants and animals: timing of ecological events; geographic distribution and range of species; species composition and the incidence of nonnative species within communities; and ecosystem processes, such as carbon cycling and storage.59,60

57 California Department of Food and Agriculture. 2022. California Agricultural Production Statistics. Available at:
https://www.cdfa.ca.gov/Statistics/
58 California Climate Change Center (CCCC). 2006. Climate Scenarios for California. 59 Parmesan, C. August 2006. Ecological and Evolutionary Responses to Recent Climate Change. 60 California, State of. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. August 27, 2018. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide_Reports-SUM-CCCA4-2018-013_Statewide_Summary_Report_ADA.pdf Attachment 10

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Appendix B
GHG Threshold Calculations

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1. BAU Forecas
t Summary
Forecast Scenario Sector Existing (2019) New (2030-2019) Total (2030) BAU Residential Energy 103,299 57,735 161,034 Residential Nonresidential Energy 147,710 43,107 190,817 Nonresidential Transportation 374,617 84,587 459,204 Residential/Nonresidential Offroad Equipment 41,425 11,085 52,510 Residential/Nonresidential Water & Wastewater 826 352 1,178 Residential/Nonresidential Solid Waste 48,506 18,050 66,556 Residential/Nonresidential Consistency Check - -

2. Demographics Forecast Summary
Category Sector Existing (2019) New (2030-2019) Total (2030) Residents 154,252 77,250 231,502
Jobs 84,625 24,697 109,322
Service Population 238,877 101,946 340,823

3. Emissions Savings Summary - Legislative savings + Playbook savings 2030 GHG Emissions (MT CO2e)
Category Measure Residential Nonresidential
Residential/
Nonresidential
Transportation Legislation - - 94,732 California Green Building Code (Title 24) 4,114 - - California RPS (SB 100) (181) (472) 13 Play 1.1: Promote 100% clean energy 983 2,316 - Play 1.2: Increase local solar photovoltaics 1 2 - Play 2.2: Support electrification of existing builings 50,313 58,621 - Play 2.3: Achieve all-electric new construction 42,783 33,003 - Play 3.1: Increase opportunities for and encourage - - 66,162 Play 3.3: Increase zero-emission vehicles - - 98,079 Play 3.4: Decarbonize off-road vehicles and equipment - - 15,753 Play 4.1: Achieve Zero Waste goals for solid waste - - 45,258 Consistency Check
(State Leg) -
Consistency Check
(Playbook) -

4. Allocate savings between existing/new and residential/nonresidential Allocation Dropdown * Savings are allocated to existing and new using the existing, new, and total demographics breakdown in section 2 and based on the logic in the Allocation column below Both * Residential + Nonresidential savings are allocated to residential and nonresidential separately the population, job, and service population demographics breakdown in section 2 Existing Only New Only
Residential Nonresidential Residential Nonresidential
BAU Forecast Consistency Check
BAU Forecast See F4:F9 403,808 312,574 144,174 70,742 - State Reductions
Transportation Legislation Both 42,874 23,522 21,471 6,865 - California Green Building Code (Title 24) New Only - - 4,114 - - California RPS (SB 100) Both (114) (362) (57) (106) - Playbook GHG Reductions
Play 1.1: Promote 100% clean energy Both 655 1,792 328 523 - Play 1.2: Increase local solar photovoltaics New Only - - 1 2 - Play 2.2: Support electrification of existing builings Existing Only 50,313 58,621 - - - Play 2.3: Achieve all-electric new construction New Only - - 42,783 33,003 - Play 3.1: Increase opportunities for and encourage
development of mixed-use sites to reduce vehicle miles
per person Play 3.2: Increase transportation options and support shared mobility Both 29,944 16,428 14,996 4,794 - Play 3.3: Increase zero-emission vehicles Both 44,389 24,353 22,230 7,107 - Manual Check: - Play 3.4: Decarbonize off-road vehicles and equipment Both 7,130 3,911 3,571 1,142 - Play 4.1: Achieve Zero Waste goals for solid waste Both 20,483 11,237 10,258 3,279 - Playbook-Adjusted Forecast
Playbook-Adjusted Forecast BAU Forecast - State Reductions - Playbook Reductions 208,134 173,071 24,479 14,133 - 34% 35% 55% 64%

5. 203
0 GHG Thresholds
Category 20
30 New Growth GHG Threshold
"Existing GHG
Thresholds"
2030 Total Population
- Per Capita Threshold
New Residential
(per resident) 0.32 1.35 1.00 New Nonresidential
(per job) 0.57 2.05 1.71 New Mixed-Use
(per service
person) 0.38 1.60 1.23

6. Summary Table
Exist
ing New Residential New Nonresidential Total
BAU Forecast 716,382 144,174 70,742 931,298 State Laws/Programs 65,919 25,528 6,759 98,206 Playbook Building Energy Measures 111,382 43,112 33,528 188,022 Playbook Transportation Measures 126,155 40,797 13,043 179,994 Playbook Waste Measures 31,720 10,258 3,279 45,258 Emissions Reductions from BAU 335,177 119,695 56,609 511,480 Remaining Total
GHG Emissions 381,2
05 24,47
9 14,13
3 419,8
18 -

7. Graphics
2030 Emissions (MT CO2e)
Annual 2030 GHG Emissions (MT CO2e)
Annual 2030 Demographics
Demographics
State Legislation
Playbook GHG Reductions
Category Allocation between existing and new Exist
ing New
Percentage reductions i
n each category

0.32 0.57

0.38 -

0.10 0.20

0.30 0.40

0.50 0.60

0.70 New Re
sidential
(per resident)
New Nonresidential
(per job)
New Mixed-Use
(per service person)
GHG Emissions
Thresholds (MT CO2e)
381,20
5 24,479
14,133
-
50,000
100,000
150,000
200,000
250,000
300,000
350,000
400,000
450,0002030
GHG Emissions (MT CO2e)
Existing New Resi
dential New Non
residential
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Appendix C
United States Green Building Council Building Area per Employee by Business Type Rates61

61 United States Green Building Council. 2008. “Building Area per Employee by Business Type.” May 13, 2008.

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Sunnyvale City CouncilJune 25, 2024

Sunnyvale City Council
June 25, 2024