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Table 3.5-1 Conshucfion and GHG Emissions CORiructlon Emissions Amortned over 30 Years 29, operabomaEmisgons Area 36 Energy 597 Waste 33 Water 29 Mobile 733 Total Project Emissions Project 5e Moe Population (Residents andEmployees) U Total Project Emissions per service population IMTC%e per service papulatlmn per year) 2AID FEIR Emissions 99,AU 201D FEIR service Population 11,794 Total 2010 FEIR Emissions per service population 93 [MTCoye perservice population per year) However, the Addendum fails to compare the Project's emissions to the relevant SCAQMD quantitative GHG threshold, instead relying upon the City of Santa Ana's 2010 Programmatic Final EIR ("FEIR"), stating: "[T]he project would not result in any new or substantially more severe GHG emissions impacts than what was analyzed in the 2010 FEIR and project GHG emissions would not be significant" (p. 3.5-2). Finally, the Addendum relies upon the Project's consistency with the City of Santa Ana's Climate Action Plan ("CAP") and CARB's 2017 Scoping Plan in order to conclude that the Project would result in a less than significant GHG impact (p. 3.5-3 - 3.5-4). However, the Addendum's quantitative and qualitative GHG analyses, as well as the subsequent less than significant impact conclusion, are incorrect for seven (7) reasons. (1) The Addendum's quantitative GHG analysis relies upon an incorrect and unsubstantiated air model; (2) The Addendum's quantitative GHG analysis relies upon an overestimated service population; (3) The Addendum fails to apply the relevant SCAQMD quantitative GHG threshold; (4) The Addendum fails to identify a potentially significant GHG impact; (5) The Addendum incorrectly relies upon the City's CAP; (6) The Addendum fails to demonstrate that the Project would be consistent with CARB's Scoping Plan; and (7) SWAPE's updated analysis indicates a potentially significant GHG impact. 20 75C-95