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3 - The Bowery_PUBLIC COMMENT_RAMSEY
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3 - The Bowery_PUBLIC COMMENT_RAMSEY
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City of Santa Ana – The Bowery <br />May 11, 2020 <br />Page 21 of 28 <br />equilibrium." (Environmental Council of Sacramento v. City of Sacramento (2006) 142 <br />Cal. App. 4th 1018, 1039.) <br />1. The Project Is Required to Adopt Additional Feasible Mitigation Measures <br />to Mitigation Construction Emissions <br />According to Mr. Hagemann and Dr. Rosenfeld, the following feasible <br />mitigation measures should also be considered and implemented to alleviate the <br />significant impact of construction-related emissions for the Project: <br />• Diesel Control Measures recommended by the Northeast Diesel <br />Collaborative (NEDC); <br />• Repowering or replacing older construction equipment engines; <br />• Installation of retrofit devices on existing construction equipment; <br />• Use of electric and hybrid construction equipment; <br />• Implementation of a construction vehicle tracking system; and <br />• Use of spray equipment with greater transfer efficiencies. <br /> (Hagemann at 14-19.) <br />2. The Project is Required to Adopt Feasible Additional Mitigation Measures to <br />Mitigate Operational Emissions <br />Second, the Project DEIR estimated the annual GHG emissions to be 9,861.60 <br />megatons per year (MT CO2e/year), which far exceeds the SCAQMD Tier 3 mixed- <br />use threshold of 3,000 MT CO2e/year. (Hagemann at 14.) In order to mitigate this <br />impact, the Project merely proposes implementing sustainable design features under <br />Title 24/CalGreen standards—but much more can and should be considered for the <br />Project. following mitigation measures for GHG emissions are feasible but were not <br />considered or implemented for the Project, including: <br />• Integrate affordable and below market rate housing; <br />• Energy-related mitigation: <br /> Install programmable thermostat timers; <br /> Establish onsite renewable energy systems, including solar power <br />and wind power;
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