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Project would additionally develop "270,000 sf of commercial (bringing the total commercial development to 1,400,000 sf)" (2019 Addendum, pp. 2627). Thus, the Project's total commercial land use size of 1,400,000 square feet includes the existing 1,130,000 square feet of commercial space, so both the existing and newly developed land uses will be operational as part of the proposed Project. As a result, the GHG emissions associated with the existing land uses and the new proposed land uses will be additive during Project operation, and the total operational emissions should be utilized to calculate GHG efficiency. Updated Greenhouse Gas Analysis Demonstrates Significant Impact In an effort to adequately evaluate the Project's GHG emissions impacts, we prepared an updated GHG emissions efficiency analysis using correct methodology. Namely, we relied upon the proposed Project's total GHG emissions, rather than the "net emissions" estimated by the 2019 Addendum. Dividing the Project's total GHG emissions of 58,835 MT CO2e/yr by a service population value of 8,001 people, we find that the Project would emit approximately 7.35 MTCOze/SP/yr (Table AQ-5, p. 119).11 When we compare the Project's per service population GHG emissions to the 2035 efficiency target of 3.0 MT CO2e/SP/yr, we find that the Project would result in a significant GHG impact (see table below). Annual Greenhouse Gas Emissions Efficiency Source Project Emissions Unit Amortized Construction+ Operational Emissions 58,835 MTCO2e/year Maximum Service Population 8,001 Per Service Population Annual Emissions 7.35 MT COze/SP/year 2035 SCAQMD Project Level Efficiency Threshold 3.0 MT CO2e/SP/year Exceed? Yes As you can see in the table above, when we compare the per service population emissions estimated by SWAPE to the SCAQMD threshold of 3.0 MTCO2e/SP/year for 2035, we find that the Project's emissions would significantly exceed the threshold, thus resulting in a potentially significant impact that was not addressed or identified in the 1983 EIR, 1996 Addendum, or 2019 Addendum. According to CEQA Guidelines § 15064.4(b), 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, a full CEQA analysis must be prepared for the project. As a result, the Applicant must prepare a Project -specific EIR which includes an updated analysis of the proposed Project's GHG emissions impacts and implements mitigation to the extent necessary. SWAPE has received limited discovery regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of v SWAPE Per Service Population Efficiency = Total Emissions / Service Population = (58,835 MTCO2e/year) / (8,001 service population) _ (7.35 MTCO2e/SP/yr)