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The Bowery Mixed -Use Proied CEQA Findinqs of Fact proposed Project would be generated off -site by fuel combustion at the electricity provider. GHG emissions from water transport are also indirect emissions resulting from the energy required to transport water from its source. GHG emissions from solid waste disposal is associated with the anaerobic breakdown of material. As shown in the Draft EIR Table 5.6-3, page 5.6-11, Section 5.6, Greenhouse Gas Emissions, the estimated increase in GHG emissions that would be generated from implementation of the proposed Project is estimated to be 9,861.60 MTCO2e per year. This exceeds the SCAQMD Tier 3 screening threshold of 3,000 MTCO2e. Therefore, additional analysis is provided based upon the direction of SCAQMD's Tier 4 thresholds through use of the City's CAP emissions targets and projected service population, which as detailed in Draft EIR Section 5.6.5, Methodology, identified a threshold of 3.16 MTCO2e per service population in the Project opening year if 2022. The Draft EIR Section 5.11, Population and Housing, shows that the Project would result in 2,081 residents and 320 employees at full occupancy. This results in a service population of 2,401 (2,081 residents + 320 employees = 2,401 service population). The Project's net increase in GHG emissions of 9,861.60 MTCO2e per year divided by the service population of the Project would result in 4.10 MTCO2e annually per service population, which exceeds the threshold of 3.16 MTCO2e per service population. Approximately 60 percent of the GHG emissions would be generated by Project mobile sources (vehicle trips). Neither the Project Applicant nor the City of Santa Ana can substantively or materially affect reductions in Project mobile -source emissions. However, the Project is an urban infill redevelopment that would provide mixed residential and commercial (retail/restaurant) uses. The site located near existing off -site employment, commercial, residential, and retail destinations and in proximity to existing public bus stops and freeways, which would result in reduced vehicle trips and Vehicle Miles Traveled (VMT) in comparison to a Project of similar size on land without close access to employment, service, and retail, destinations; in addition to public transit and freeways. The California Air Pollution Control Officers Association (CAPCOA) has provided guidance for mitigating or reducing transportation related VMT from land use development projects within its guidance document titled Quantifying Greenhouse Gas Mitigation Measures (CAPCOA 2010). The land use characteristics of the Project are consistent with the CAPCOA guidance related to a reduction of VMT: • Area Density: CAPCOA identifies that increases in area density, measured in terms of persons, jobs, or dwelling units per unit area, reduces VMT associated with transportation, as it reduces the distance people travel for work or services and provides a foundation for the implementation of other strategies such as enhanced transit services (CAPCOA guidance measure LUT-1). According to CAPCOA, the reduction in VMT from increases in area density applies to urban and suburban settings for residential, retail, office, industrial, and mixed - use projects. The urban infill/redevelopment Project would provide residential, retail/restaurant, and employment uses and is located near other employment opportunities, services, and retail commercial uses. The proposed Project would provide an increase in area residential density and an improvement to the jobs -housing balance. As detailed in Section 5.1 1, Population and Housing, the Project region has an existing and projected future imbalance between the number of jobs and housing units. Thus, per CAPCOA guidance, the City of Santa Ana 48 May 2020 75C-466