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(1) Incorrect and Unsubstantiated Quantitative GHG Analysis As discussed above, the Addendum estimates that the Project would generate net annual GHG emissions of 1,493 MT CO2e/year, resulting in a service population efficiency of 2.0 MT CO2e/SP/year (p. 3.5-2, Table 3.5-1). However, the Addendum's quantitative GHG analysis should not be relied upon, as it relies upon an unsubstantiated air model. As previously discussed, when we reviewed the Project's CaIEEMod output files, provided in the Air Quality Assessment as Appendix B to the Addendum, we found that several of the values inputted into the model are not consistent with information disclosed in the Addendum and associated documents. As a result, the model underestimates the Project's GHG emissions, and the Addendum's quantitative GHG analysis should not be relied upon to determine Project significance. An EIR should be prepared that adequately assesses the potential GHG impacts that construction and operation of the proposed Project may have on the surrounding environment. (2) Reliance Upon an Overestimated Service Population As discussed above, the Addendum concludes that the Project would result in a service population efficiency value of 2.0 MT CO2e/SP/year, based on a service population value of 747 people (p. 3.5-2, Table 3.5-1). However, the Addendum's quantitative GHG analysis is unsubstantiated, as it relies upon an unsupported service population of 747 people. According to CAPCOA's CEQA & Climate Change report, service population is defined as "the sum of the number of residents and the number of jobs supported by the project."31 The Addendum indicates that the proposed Project would provide housng for up to 507 residents, "[u]sing the household size ratio from the 2010 FOR of 3.0 persons per household" (p. 3.9-5). However, this household size ratio should not be relied upon as it is from approximately 10 years ago and fails to take into account the type of housing development or number of units per structure. Rather, the more recent 2020 Draft Program Environmental Impact Report ("DPEIR") for the City of Santa Ana General Plan Update reveals that this value is incorrect. Rather, the DPEIR indicates that structures including over 50 units would have household size ratios of 2.77- and 2.45-persons per household 2018 and 2045, respectively (see excerpt below).32 Table 4: Persons per Household Assumptions Units in Structure 2000 2010 2011 2D12 2D13 2D14 2015 2016 2017 2018 2045 Citywide 4.37 4.30 4.26 4.41 4.14 3.97 4.33 4.20 4.11 3.97 3.62 Single family' 5.09 4.92 4.98 4.94 4.84 4.81 5-OD 4.95 4.73 4.693 4.30^ Mugs-famil2 4.07 4.01 3.86 4.15 3.82 3.51 4.01 3.66 3.74 3.583 3.124 2 to 4 440 484 409 477 390 356 449 4.37 4.01 403 343 5 tc 19 393 378 375 431 369 355 401 3.85 3.53 399 3 60 20 to 49 467 420 435 449 431 381 4.1 D 420 3.92 50 or more 3.71 3.58 3.67 3.55 3.71 3.19 3A3 3.18 3.74 2.77 2.41 " CAPCOA (Jan. 2008) CEQA & Climate Change, p. 71-72, http://www.capcoa.org/wp- conte nt/up load s/2012/03/CAPCOA-W h ite-Pa per. pd f. 32 "Santa Ana General Plan Update Draft Program Environmental Impact Report." August 2020, available at: htti)s://www.sa nta-a na.ora/sites/d efa u It/files/D b/ae ne ra (- plan/documents/Draft%20EIR/Complete%20Draft%20PEIR.i)df, p. B-b-11, Table 4. 21 75C-96