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energy use. As such, the proposed Project is not consistent with this measure and the Addendum lacks substantial evidence to support its consistency determination. Require the use of energy -efficient lighting for all Here, the while the Addendum states that the street, parking, and area lighting "project would use utilize energy -efficient LED lighting," the Addendum and associated documents fail to mention or specify that energy - efficient lighting would be require for all street, parking, and area lighting, as the measure states (p. 3.5-3). As such, the proposed Project is not consistent with this measure and the Addendum lacks substantial evidence to support its consistency determination. Require the landscaping design for parking lots to Here, the Addendum and associated documents utilize tree cover and compost/mulch fail to mention or require the landscaping design for parking lots to utilize tree cover and compost/mulch, as the measure indicates. As such, the proposed Project is not consistent with this measure and the Addendum lacks substantial evidence to support its consistency determination. Incorporate water retention in the design of Here, the Addendum and associated documents parking lots and landscaping, including using fail to mention or incorporate water retention in compost/mulch the design of parking lots and landscaping, including using compost/mulch. As such, the proposed Project is not consistent with this measure and the Addendum lacks substantial evidence to support its consistency determination. Require the development project to propose an Here, the Addendum and associated documents off -site mitigation project which should generate fail to mention or require the Project to propose an carbon credits equivalent to the anticipated GHG off -site mitigation project to generate carbon emission reductions. This would be implemented credits, as required. As such, the proposed Project via an approved protocol for carbon credits from is not consistent with this measure and the California Air Pollution Control Officers Association Addendum lacks substantial evidence to support its (CAPCOA), the California Air Resources Board, or consistency determination. other similar entities determined acceptable by the local air district Require the project to purchase carbon credits Here, the Addendum and associated documents from the CAPCOA GHG Reduction Exchange fail to require the Project to purchase carbon Program, American Carbon Registry (ACR), Climate credits whatsoever. In addition, the Addendum and Action Reserve (CAR) or other similar carbon credit associated documents fail to mention the CAPCOA registry determined to be acceptable by the local GHG Reduction Exchange Program, ACR, CAR, or air district other similar carbon credit registries. As such, the proposed Project is not consistent with this measure and the Addendum lacks substantial evidence to support its consistency determination. 29 75C-104