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22 <br /> <br /> <br />As you can see in the excerpt above, the Addendum concludes that the Project will produce 2,231 MT <br />CO2e/year from construction and operation. However, this is incorrect for two reasons. <br />First, the Addendum’s CalEEMod model relies upon incorrect input parameters to estimate the Project’s <br />criteria air pollutant and GHG emissions, resulting in an underestimation of Project emissions. <br />Therefore, we find the Addendum’s quantitative GHG analysis to be incorrect and unreliable. <br />Furthermore, the Addendum should have compared the Project’s quantified GHG emissions to the 2030 <br />substantial progress service population efficiency threshold of 3.0 MT CO2e/SP/year, as the Project’s <br />development would occur beyond 2020 and the Project would become operational in 2022. We <br />calculated the Project’s service population by totaling the Project’s anticipated residents and <br />employees.26 If the correct threshold had been used to adequately evaluate the Project’s emissions, a <br />significant impact would be revealed that was not previously identified in the Addendum (see table <br />below). <br />Annual Greenhouse Gas Emissions Efficiency <br />Source Project Emissions Unit <br />Addendum Annual Emissions 2,231 MT CO2e/year <br />Maximum Service Population 653 Residents &Employees <br />Per Service Population Annual Emissions 3.42 MT CO2e/sp/year <br />2035 SCAQMD Project Level Efficiency Threshold 3.0 MT CO2e/sp/year <br />Exceed? Yes - <br /> <br />26 Service Population = Residents + Employees = 629 + 24 = 653; <br />Residents identified as 629 (Appendices, pp. 135); Employees identified as approximately 24 (13,350 / 549), see <br />“Building Area Per Employee By Business Type.” USGBC, May 2008, available at: <br />https://www.usgbc.org/drupal/legacy/usgbc/docs/Archive/General/Docs4111.pdf <br />