Item 18 - Appeal Application Nos. 2023-02 and 2023-03 for Cabrillo Town Center project

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• Scope 3: Indirect emissions associated with other emissions sources, such as third -party vehicles and embodied energy (e.g., energy used to convey, treat, and distribute water and wastewater).63 The General Reporting Protocol provides a range of basic calculations methods. However, the General Reporting Protocol calculations are typically designed for existing buildings or facilities. These retrospective calculation methods are not directly applicable to planning and development situations where buildings do not yet exist. CARB recommends consideration of indirect emissions to provide a more complete picture of the GHG emissions footprint of a facility. Annually reported indirect energy usage aids the conservation awareness of a facility and provides information to CARB to be considered for future strategies.64 For example, CARB has proposed requiring the calculation of direct and indirect GHG emissions as part of the AB 32 reporting requirements. Additionally, OPR has noted that lead agencies "should make a good - faith effort, based on available information, to calculate, model, or estimate... GHG emissions from a project, including the emissions associated with vehicular traffic, energy consumption, water usage and construction activities."65 Therefore, direct and indirect emissions have been calculated for the Project. A fundamental difficulty in the analysis of GHG emissions is the global nature of the existing and cumulative future conditions. Changes in GHG emissions can be difficult to attribute to a particular planning program or project because the planning effort or project may cause a shift in the locale for some type of GHG emissions, rather than causing "new" GHG emissions. As a result, there is an inability to conclude whether a project's GHG emissions represent a net global increase, reduction, or no change in GHG emissions that would exist if the project were not implemented. The analysis of the Project's GHG emissions is particularly conservative in that it assumes all the GHG emissions are new additions to the atmosphere. Construction The Project's construction emissions were calculated using CaIEEMod Version 2022.1.1.14. Details of the modeling assumptions and emission factors are provided in the Technical Appendix. CaIEEMod calculates emissions from off -road equipment usage and on -road vehicle travel associated with haul, delivery, and construction worker trips. GHG emissions during construction were forecasted based on the proposed construction schedule and included the mobile source and fugitive dust emissions factors derived from CaIEEMod. The calculations of the emissions generated during Project construction activities reflect the types and quantities of construction equipment that would be used to remove existing pavement, grade, and 63 Embodied energy is a scientific term that refers to the quantity of energy required to manufacture and supply to the point of use a product, material, or service. 64 California Air Resources Board, Initial Statement of Reasons for Rulemaking, Proposed Regulation for Mandatory Reporting of Greenhouse Gas Emissions Pursuant to the California Global Warming Solutions Act of 2006 (AB 32), Planning and Technical Support Division Emission Inventory Branch, October 19, 2007. 65 OPR Technical Advisory, p. 5. Cabrillo Town Center Greenhouse. as ec PAGE 28 18 — 993 City of Santa Ana 10/3/2023 July 2023