Are 270 electoral votes ACTUALLY required to win?

The 12th Amendment says, "The person having the greatest number of votes for President, shall be the President, if such number be a majority of the whole number of Electors appointed[.]"

Joseph E. Schmitz wrote a Discussion Draft titled, "January 6, 2021, Will Be Vice President Pence’s Biggest Day in Congress" (link below). In that document he mentions, "the necessary 270 electoral votes to win the election," as if it is a fact not in question (pg. 3, p. 6). But, he then essentially contradicts that supposed fact by paraphrasing the precept expressed in Hubbard v. Lowe, "An unconstitutionally appointed elector, like an unconstitutionally enacted statute, is no elector at all." (pg. 4, p. 10)

If electors' ballots are not counted due to them not being constitutionally appointed, that would reduce the total number of electors duly appointed and, therefore, the number representing a majory of such. Correct? Lawfags?

Source quoted: https://everylegalvote.com/assets/pdfs/January_6_2021_Will_Pence_s_Biggest_Day_in_Congress.pdf