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the project to calculate the land use index, as stated in the measure. As such, this measure is unsubstantiated, and the model should not be relied upon to determine Project significance. Water Measures Measure WUW-1 Install Low -Flow Water Fixtures As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults "Installing low flow or high -efficiency water fixtures be justified. Here, however, the "User Entered in buildings reduces water demand, energy Comments & Non -Default Data" table fails to demand, and associated indirect GHG emissions." mention or substantiate the inclusion of this The following information needs to be provided by measure whatsoever (Appendix B. pp. 79, 111, the Project Applicant: 231). While the Addendum states that the • Total expected indoor water demand, proposed Project's water demand is 29.6 acre - without installation of low -flow or high- feet per year ("AFY"), the Addendum fails to efficiency fixtures (million gallons), AND specify whether this total expected water • Total expected indoor water demand, after demand is after the installation of low -flow or installation of low -flow or high -efficiency high -efficiency fixtures. Thus, the Addendum fixtures (million gallons), OR and associated documents fail to provide the • Commitment to low -flow or high -efficiency total expected indoor water demand, without water fixtures (toilets, showerheads, sink installation of low -flow or high -efficiency faucets, dishwashers, clothes washers, or fixtures, and total expected indoor water all of the above) demand, after installation of low -flow or high - efficiency fixtures, or a commitment to low - flow or high -efficiency water fixtures, as is required in the measure. Furthermore, the Addendum states that "[t)he project would utilize energy -efficient LED lighting, a drought tolerant plant palette, and low -flow water fixtures to increase building sustainability" (p. 3.5-3). However, the Addendum only states this to demonstrate consistency with the City's Climate Action Plan ("CAP"). Thus, the Project fails to include low -flow water fixtures as a product design feature or mitigation measure, and the Addendum fails to demonstrate that the Project actually intends to install low -flow water fixtures at the Project site. As such, this measure is unsubstantiated, and the model 12 75C-87