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12 (1) Failure to Demonstrate Consistency with the FEIR According to the Addendum, “the project would not result in any new or substantially more severe GHG emissions impacts than what was analyzed in the 2010 FEIR and project GHG emissions would not be significant. Mitigation Measures 4.13-8 through 4.13-23 from the 2010 FEIR would be applicable to the proposed project” (p. 3.5-2). However, this is incorrect, as the Addendum fails to substantiate this conclusion. Review of the Addendum demonstrates that several of the mitigation measures identified in the 2010 FEIR are not substantiated or implemented in the Addendum. According to the Addendum, “[M]itigation measures applied to the proposed project include all diesel fuel construction equipment classified Untied States Environmental Protection Agency (USEPA) Tier II or better (Mitigation Measure 4.13-1), all construction equipment shut off when not in use and not idling for more than five minutes (Mitigation Measure 4.13-2), electrical powered equipment used to the extent feasible(Mitigation Measure 4.13-5), exceedance of Title 24 requirements (Mitigation Measure 4.13-8), drought tolerant landscaping (Mitigation Measure 4.13-9), low flow showers and faucets in residences (Mitigation Measure 4.13- 10), ride sharing programs (Mitigation Measure 4.13-16), fluorescent lighting (Mitigation Measure 4.13-17), and 10 percent renewable energy for the commercial project component (Mitigation Measure 4.13-24)” (p. 3.5-1). However, this justification and attempt at compliance with the FEIR is incorrect for several reasons. First, the Addendum fails to actually commit to the use of these mitigation measures or discuss how they will be implemented, monitored, and enforced. Without further analysis by the Addendum describing how the proposed Project will apply these mitigation measures, we cannot assume that they will be implemented or enforced. Furthermore, the Addendum fails to address several of the mitigation measures between 4.13-8 through 4.13-23 that are included in the FEIR (see table below). Measure Addendum Consistency 2010 Santa Ana Transit Zoning Code FEIR22 Construction Measures MM 4.13-1 All diesel fueled construction equipment shall be classified EPA Tier II or better emission efficiencies. Here, the Addendum states that the Project will “include all diesel fuel construction equipment classified United States Environmental Protection Agency (USEPA) Tier II or better” (p. 3.5-1). However, this is all that is stated and as such, the Addendum fails to demonstrate a commitment to implementation, monitoring, and enforcement of the measure. Thus, we cannot verify that all diesel- 22 “Transit Zoning Code Environmental Impact Report.” City of Santa Ana, May 2010, available at: https://www.santa-ana.org/sites/default/files/Documents/18_Sec4-13_GlobalClimateChange.pdf, Chapter 4.13, Global Climate Change.