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Measure LUT-1 Increase Density <br />'The reductions in GHG emissions are quantified <br />based on reductions to VMT. The relationship <br />between density and VMT is described by its <br />elasticity." <br />VMT Reduction = A * B, where: <br />A = % increase in housing units orjobs/acre <br />B = Elasticity of VMT with respect to density <br />The following information needs to be provided by <br />the Project Applicant: <br />• Number of housing units per acre or jobs <br />per job acre <br />Measure LUT-3 Increase Diversity <br />"Having different types of land uses near one <br />As previously mentioned, the CalEEMod User's <br />Guide requires any changes to model defaults <br />be justified. Here, however, the "User Entered <br />Comments & Non -Default Data" table fails to <br />mention or substantiate the inclusion of this <br />measure whatsoever (Appendix B, pp. 79, 111, <br />231). While the Greenhouse Gas ("GHG") <br />Emissions Assessment, provided by Appendix D <br />to the Addendum, states that the Project <br />"would result in 169 dwelling units per acre <br />over the 2.715-acre site," the Addendum and <br />associated documents completely fail to <br />mention or evaluate the increased density <br />"based on reductions to VMT." as stated in the <br />measure (Appendix D, pp. 217). The Addendum <br />and associated documents also fail to mention <br />the % increase in housing units or jobs/acre or <br />the elasticity of VMT with respect to density, as <br />stated in the measure. Finally, the Addendum <br />and associated documents fail to provide any <br />calculations or assumptions used to include this <br />measure in the model. As such, this measure is <br />unsubstantiated, and the model should not be <br />relied upon to determine Project significance. <br />As previously mentioned, the CalEEMod User's <br />Guide requires any changes to model defaults <br />be justified. Here, however, the "User Entered <br />another can decrease VMTsince trips between land I Comments & Non -Default Data" table fails to <br />use types are shorter and may be accommodated <br />by non -auto modes of transport." <br />The following information needs to be provided by <br />the Project Applicant: <br />• Percentage of each land use type in the <br />project (to calculate land use index) <br />11 <br />mention or substantiate the inclusion of this <br />measure whatsoever (Appendix B, pp. 79, 111, <br />231). In regard to Measure LUT-3, the GHG <br />Emissions Assessment states: "The measure <br />requires at least three different land uses <br />within 0.25 mile. The Project proposes <br />residential, retail, and restaurant uses, and <br />there are also residential, retail, and office land <br />uses within this distance from the Project" <br />(Appendix D, pp. 217). However, the <br />Addendum and associated documents fail to <br />provide the percentage of each land use type in <br />75C-86 <br />