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4.Written Comments on the Draft EIR and Responses to Comments infrastructure becomes available. Developers of projects within the EDZ area would also be required to comply with the California Green Building Standards Code and Model Water Efficient Landscape Ordinance requirements. The Draft SEIR did include an incidental calculation of water use as part of the analysis of greenhouse gas(GHG)emissions and energy impacts, using the CalEEMod land use emissions model. The output from the CaIEEMod model can be found in Appendix F of the Draft SEIR. With regards to estimates of water use,the model relies on statewide average water demand figures that are generally conservative(e.g.,that it may estimate water use as greater than what would actually occur) when compared with project-or area-specific water use planning calculations. For instance,the CaIEEMod water use assumptions are substantially higher than those used in the City's 2004 Water Master Plan. The Water Master Plan assumed water demand of 70 gallons per day(gpd) per 1,000 square feet(sf)of retail use, while CalEEMod(based on a 2003 Pacific Institute report, Waste Not, Want Not: The Potential for Urban Water Conservation in California)assumes 203 gpd (indoor use only)per 1,000 sf of retail use. It is therefore likely that the actual water demand of the proposed EDZ would be far less than that projected under the CalEEMod model. Using the City's Water Master Plan rates, indoor water use represented by full buildout of the EDZ would be approximately 3.8 million gallons per year(gpy),compared to the nearly 11 million gpy assumed using the CalEEMod model. Even assuming outdoor water use at the same ratio as that used in the CalEEMod model, total water use for the club retail store using the City's Water Master Plan rates would be 6.1 million gpy,45 percent less than assumed using the CalEEMod water use rates. Nevertheless,the model can be instructive in comparing estimated water consumption rates of different land uses relative to one another. The table in Appendix F of the Draft SEIR estimates total annual water use at full buildout of the EDZ to be approximately 57.4 million gpy. Using the same water demand rates, existing water use within the EDZ is estimated at 31.7 million gpy, meaning the proposed EDZ would result in an increase of approximately 81 percent. However, the square footage of the various uses within the fully built-out EDZ would increase from approximately 225,000 sf to approximately 510,000 sf, an increase of approximately 127 percent. These figures suggest that the altered land uses at the site would be substantially more efficient in their use of water than the uses that are currently present: water use per square foot would decrease by 20 percent. In addition,a large area of the EDZ area was occupied, until 2013, by a Clorox Company research and development facility. Using the same water demand factors,total water usage on the project site at the time that facility was operating(assuming the facility was half office and half industrial)was more than twice what would be used by the proposed EDZ at full buildout, and almost four times existing water use on the site. Finally, it is also noted that, were the project site to be built out as permitted under existing zoning in accordance with the No Project Alternative described in Chapter 5 of the Draft SEIR (largely office uses),total water usage would be nearly 90 percent of the amount that would be associated with the proposed EDZ, and nearly 3.5 times the volume of water represented by the existing uses on the site. As noted in the EDZ Design Guidelines(see Appendix D of the Draft SEIR), standard conditions of approval for all new development within the EDZ would require the use of drought-tolerant Johnson Dnve Economic Development Zone 4-14 ESA 1 140421 Supplemental EIR Response to Comments March 2016