5A Public Hearings 2021 0706 - Laserfiche WebLink

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5 As you can see in the excerpt above, the CH4, CO2, and N2O intensity factors were reduced by approximately 52%, 76%, and 67%, respectively. As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.6 According to the “User Entered Comments and Non‐Default Data” table, the justification provided for these changes is: “Based on the 2019 EBCE Power Content Label” (Appendix A, pp. 129). Furthermore, regarding the Project’s anticipated utility company, the Checklist states: “Electrical needs to the project site would be provided by East Bay Clean Energy (EBCE). EBCE obtains electricity from conventional and renewable sources throughout California. In 2019, 59.9 percent of the electricity from EBCE’s Bright Choice Power Mix was generated from renewable energy sources; 25.3 percent from large hydroelectric generators; 1.5 percent from nuclear sources; and 13.3 percent from other and unspecified sources” (p. 4‐42). However, these changes remain unsupported, as the 2019 EBCE Power Content Label fails to provide the revised intensity factors. Furthermore, review of the 2019 EBCE Power Content Label demonstrates that East Bay Clean Energy provides four categories of power mixes (Renewable 100, Brilliant 100, Bright Choice, and 2019 CA Power Mix). Without additional information regarding which power mix the Project would use, we cannot verify the revised intensity factors. As a result, the changes remain unsupported. These unsubstantiated reductions present an issue, as CalEEMod uses the CH4, CO2, and N2O intensity factors to calculate the Project’s greenhouse gas (“GHG”) emissions associated with electricity use.7 Thus, by including unsubstantiated reductions to the default CH4, CO2, and N2O intensity factors, the models may underestimate the Project’s GHG emissions. Therefore, the Project may have significant GHG impacts that would not be substantially mitigated by the mitigation measures listed in the checklist and General Plan EIR. Unsubstantiated Reductions to Off‐Road Construction Equipment Usage Hours Review of the CalEEMod output files demonstrates that the “Callan and E 14th Street Infill Checklist Project Construction” and “Callan and E 14th Street Infill Checklist Project Mitigated Construction” models include reductions to the default off‐road construction equipment usage hours (see excerpt below) (Appendix A, pp. 84, 107). As you can see in the excerpt below, the usage hours for two pieces of off‐road construction equipment were reduced from the default value to 1‐hour. As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.8 According to the “User Entered Comments and Non‐Default Data” table, the justification provided for these changes is: “crane and welders would only 6 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 7 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.caleemod.com/, p. 17. 8 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 120