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Measure WUW-4 Use Water -Efficient Landscape Irrigation Systems "Using water -efficient landscape irrigation techniques such as "smart" irrigation technology reduces outdoor water demand, energy demand, and the associated GHG emissions." The following information needs to be provided by the Project Applicant: • Total expected outdoor water demand, without installation of smart landscape irrigation controller (million gallons). • (Optional) Project -specific percent reduction in outdoor water demand, after installation of smart landscape irrigation controller. Percent reduction must be verifiable. Otherwise, use the default value of 6.1%. should not be relied upon to determine Project significance. As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be justified. Here, however, the "User Entered Comments & Non -Default Data" table fails to mention or substantiate the inclusion of this measure whatsoever (Appendix B, pp. 79, 111, 231). Furthermore, the Addendum states that "water -efficient irrigation systems would be used" (p. 3.5-4). However, the Addendum only states this to demonstrate consistency with CARB's 2017 Scoping Plan. Thus, the Project fails to include water -efficient landscape irrigation systems as a product design feature or mitigation measure, and the Addendum fails to demonstrate that the Project actually intends to implement water -efficient landscape irrigation techniques at the Project site. Furthermore, the Addendum and associated documents fail to provide the total expected outdoor water demand, without installation of smart landscape irrigation controller and/or the Project -specific percent reduction in outdoor water demand, after installation of smart landscape irrigation controller, as required in the measure. As such, this measure is unsubstantiated, and the model should not be relied upon to determine Project significance. As shown above, the Addendum fails to justify several of the mitigation measures utilized in the Project's CalEEMod model according to the relevant guidance. As a result, the inclusion of these measures in the model is unsubstantiated and the model should not be relied upon to determine the significance of GHG impacts from the Project. Diesel Particulate Matter Health Risk Emissions Inadequately Evaluated The Addendum concludes that the Project's health risk impacts would be less than significant without conducting a quantified construction or operational health risk assessment ("HRA") (p. 6). Specifically, regarding the health risk impacts associated with Project construction, the Addendum states: 13 75C-88