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factor to calculate the Project's greenhouse gas ("GHG") emissions associated with electricity use.' Thus,
<br />by including an underestimated CO2 intensity factor, the model underestimates the Project's GHG
<br />emissions and should not be relied upon to determine Project significance.
<br />Use of an Underestimated Land Use Size
<br />According to the Addendum, the proposed Project on Block A would include:
<br />"a mixed -use residential structure containing 99 apartment units, with approximately 93,117
<br />square feet of residential space, 8,075 square feet of leosinalomenity areas, a 3,847-square foot
<br />restaurant, and 7,514 square feet of retail space. On Block B, a 70-unit multi -family residential
<br />structure would be constructed, with 74,986 square feet of residential space, as well as an
<br />aboveground parking structure with approximately 192 stalls" (emphasis added) (p. 2-10).
<br />Thus, the Project would include 8,075-SF of leasing/amenity areas, in addition to the proposed 93,117-
<br />SF of residential land use space on Block A and 74,986-SF of residential land use space on Block B. As
<br />such, the Project's CalEEMod should have a total of 176,178-SF of residential land use space.7 However,
<br />review of the Project's CalEEMod output files demonstrate that the model includes only 169,000-SF of
<br />"Apartments Mid Rise" (see excerpt below) (Appendix B, pp. 78, 110, 230).
<br />Lend uses
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<br />1..__••__••__•I•__••__••__••__••_f__•___..__.._-0..................
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<br />.......
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<br />9
<br />.......
<br />Apea sMy Rise
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<br />0
<br />As you can see in the excerpt above, the "Apartment Mid Rise" land use was underestimated by 7,178-
<br />SF. This underestimation presents an issue, as the land use size feature is used throughout CalEEMod to
<br />determine default variable and emission factors that go into the model's calculations. The square
<br />footage of a land use is used for certain calculations such as determining the wall space to be painted
<br />(i.e., VOC emissions from architectural coatings) and volume that is heated or cooled (i.e., energy
<br />impacts). Furthermore, CalEEMod assigns each land use type with its own set of energy usage emission
<br />factors.' By underestimating the proposed residential land use size, the model underestimates the
<br />Project's construction -related and operational emissions and should not be relied upon to determine
<br />Project significance.
<br />Unsubstantiated Changes to Individual Construction Phase Lengths
<br />Review of the Project's CalEEMod output files demonstrates that the model includes unsubstantiated
<br />changes to the Project's anticipated individual construction phase lengths (see excerpt below) (Appendix
<br />B, pp. 80, 112, 232).
<br />6 "CalEEMod User's Guide." CAPCOA, November 2017, available at: http://www.caleemod.com/, p. 17.
<br />7 (93,117-SF of residential space on Block A) + (8,075-SF of leasing/amenity areas on Block A) + (74,986-SF of
<br />residential space on Block B) = 176,178-SF total.
<br />e "CalEEMod User's Guide, Appendix D." CAPCOA, September 2016, available at:
<br />http://www.agmd.gov/docs/default-source/caleemod/upgrades/2016.3/05 appendix-d2016-3-1.pdf?sfvrsn=2
<br />75C-78
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