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9. Page 35-36: I would challenge the assertion that the project "would not have a significant effect <br /> on the environment" based on the convoluted and illogical arguments presented on page 35 <br /> and 36.This appears to be a manipulation of existing environmental law to benefit Costco and <br /> the project. Please provide a legal analysis and peer-reviewed interpretation of the arguments <br /> made on these pages for this finding. <br /> 10. Table 6: What percentage is the full JDEDZ buildout of 15 million tons annually of GHG emission <br /> to the total retail and overall total emissions in the city? How does this increase compare to <br /> annual GHG reductions goals in the city as required by the CAP? <br /> 11. Page 40: Provide the legal basis and criteria for using a "qualitative" analysis when sufficient <br /> data exists to perform a "quantitative"analysis? <br /> 12. Page 40, bottom of page: Same comment as#7 and#8. <br /> 13. Page 41: Please elaborate on the logic that a project that creates 15 million tons of GHG <br /> emissions per year helps meet and is consistent with the 2017 Scoping Plan update. Explain <br /> how this is not an inversion of the intent of California law to reduce GHG emissions. <br /> 14. Table 7: Please provide similar information of how the JDEDZ is consistent or inconsistent with <br /> the General Plan Sustainability policies and goals. <br /> 15. Page 46,Conclusion: The city seems to be basing their judgement of the effects of GHG <br /> emissions compared to that of global GHG emissions and global climate change. It is precisely <br /> the cumulative impacts of thousands of projects just like this one (and other activities)that have <br /> created global climate change. Identify the CEQA provision that permits an evaluation of project <br /> GHG emissions significance compared to global GHG emissions. <br /> Economic Analysis <br /> 1. The Economic Analysis was performed in 2016 prior to the planning and construction of new <br /> retail and other projects in the Tri Valley. Please update the assumptions for newly constructed <br /> or planned projects, including the new IKEA in Dublin, not included in the 2016 analysis and re- <br /> evaluate the economic impacts of Costco. <br /> 3 <br />