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