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Consider generating or purchasing local and <br />California -only carbon credits as the preferred <br />mechanism to implement its offsite mitigation <br />measure for GHG emissions and that will facilitate <br />the State's efforts in achieving the GHG emission <br />reduction goal <br />Here, the Addendum and associated documents <br />fail to consider or indicate that the proposed <br />Project will generate or purchase any local or <br />California -only carbon credits. As such, the <br />proposed Project is not consistent with this <br />measure and the Addendum lacks substantial <br />evidence to support its consistency determination <br />As the above table indicates, the Addendum and associated documents fail to provide sufficient <br />information and analysis to determine Project consistency with various measures under CARB's 2017 <br />Scoping Plan. Thus, we cannot verify that the Project would be consistent with CARB's 2017 Scoping <br />Plan, as stated in the Addendum. As a result, we recommend that an EIR be prepared to include further <br />information and analysis demonstrating the Project's consistency. <br />(7) Updated Analysis Indicates a Potentially Significant GHG Impact <br />Applicable thresholds and site -specific modeling demonstrate that the proposed Project would result in <br />a significant GHG impact not previously mitigated by the Addendum. The CalEEMod output files, <br />modeled by SWAPE with Project -specific information, disclose the Project's mitigated emissions, which <br />include approximately 996 MT CO2e of total construction emissions (sum of 2021, 2022, and 2023) and <br />approximately 1,993 MT CO2e/year of net annual operational emissions (sum of area, energy, mobile, <br />waste, and water -related emissions), for a net annual GHG emissions of 2,026 MT CO2e/year. <br />Furthermore, as described above, we estimate that the Project's total service population would be <br />approximately 430 people. When dividing the Project's GHG emissions (amortized construction + <br />operational) by a service population value of 430 people, we find that the Project would emit <br />approximately 4.71 MT CO2e/SP/year.44 As demonstrated in the table below, the service population <br />efficiency value of 4.71 MT CO2e/SP/year exceeds the SCAQMD 2035 efficiency target of 3.0 MT <br />CO2e/SP/year (see table below).41 <br />SWAPE Service Population Efficiency <br />Proposed <br />Project Phase Project (MT <br />Construction (amortized over 30 years) <br />33.21 <br />Area <br />37.63 <br />Energy <br />599.40 <br />Mobile <br />1,214.56 <br />Waste 66.11 <br />Water 75.23 <br />"Calculated: (2,026.12 MT CO2e/year) / (430 service population) _ (4.71 MT CO2e/SP/year). <br />45 "Minutes for the GHG CECA Significance Threshold Stakeholder Working Group #15." SCAQMD, September <br />2010, available at: http://www.agmd.gov/docs/default-source/cega/handbook/greenhouse-gases-(aha)-cega- <br />sianificance-thresholds/year-2008-2009/aha-meeting-15/aha-meeting-15-minutes.pdf, p. 2. <br />30 <br />75C-105 <br />