5A Public Hearings 2021 0706 - Laserfiche WebLink

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23 Furthermore, based on a service population of 621 people, the Checklist estimates a service population efficiency value of 0.76 metric tons of carbon dioxide equivalents per service population per year (“MT CO2e/SP/year”), which would be less severe than the 2035 General Plan (p. 4‐55). Finally, the Checklist relies upon the Project’s consistency with CARB’s Scoping Plan, the Plan Bay Area, and the City of San Leandro Climate Action Plan (“CAP”) (p. 4‐56 ‐ 4‐59). However, the Checklist’s GHG analysis, as well as the subsequent less‐than‐significant impact conclusion, is incorrect for three reasons. (1) The Checklist’s quantitative GHG analysis relies upon an incorrect and unsubstantiated air model; (2) Updated analysis indicates a potentially significant GHG impact; and (3) The Checklist fails to consider the performance‐based standards under CARB’s Scoping Plan. 1) Incorrect and Unsubstantiated Quantitative Analysis of Emissions As previously stated, Checklist estimates that the Project would generate net annual GHG emissions of 472 MT CO2e/year (p. 4‐55, Table 4‐8). However, the Project’s quantitative GHG analysis is unsubstantiated. As previously discussed, when we reviewed the Project's CalEEMod output files, provided in the AQ & GHG Report as Appendix A to the Checklist, we found that several of the values inputted into the model are not consistent with information disclosed in the Checklist. As a result, the model underestimates the Project’s emissions, and the Project’s quantitative GHG impacts remain significant and substantially unmitigated. 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) Updated Analysis Indicates a Potentially Significant GHG Impact In an effort to more accurately estimate Project emissions, we prepared updated CalEEMod models, using the Project‐specific information provided by the Checklist. In our updated models, we omitted the unsubstantiated changes to the CO2, CH4, and N2O intensity factors, off‐road construction equipment usage hours, operational vehicle fleet mix percentages, gas fireplace values, energy use values, outdoor water use rates, and wastewater system treatment percentages; corrected the indoor water use rate; and excluded the unsubstantiated construction‐related and operational mitigation measures. When applying the AEP’s “2030 Land Use Efficiency Threshold” of 2.6 MT CO2e/SP/year, SWAPE’s updated modeling demonstrates a potentially significant GHG impact not previously identified or mitigated by the Checklist. The updated CalEEMod output files, modeled by SWAPE with Project‐specific information, disclose the Project’s mitigated emissions, which include approximately 806 CO2e of total construction emissions (sum of 2021, 2022, and 2023) and approximately 6,268 MT CO2e/year of net annual operational emissions (sum of area‐, energy‐, mobile‐, waste, and water‐related emissions). When amortizing the Project’s construction‐related GHG emissions over a period of 30 years and summing them with the Project’s operational GHG emissions, we estimate net annual GHG emissions of 6,295 MT CO2e/year. When dividing the Project’s GHG emissions (amortized construction + operational) 138