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MainPlace Transformation Project City Council Agenda Item 75D June 4, 2019 Page 10 C. There is Substantial Evidence Supporting a Fair Argument that the Project Will Result in a Significant Construction -Related Air Quality Impact. As discussed below, the Addendum is inadequate because it does not calculate the Project's construction -related criteria air pollutant emissions. As a result, it makes it impossible to accurately determine whether or not the Project will have a significant impact from construction -related criteria air pollutant emissions. The Addendum does, however, include a California Emissions Estimator Model Version CalEEMOd.2016.3.2 ("CalEEMod") air model for the Project's construction GHG emissions. But even this data is incomplete because the Addendum only provides the annual CalEEMod modeling, and does not include the summer or winter output files. SWAPE, p. 4. The summer and winter output files are necessary because the annual output files calculate emissions as total tons per year. In contrast, the summer and winter output files estimate emissions as the maximum pounds per day, which is the same metric used for SCAQMD's significance threshold. SWAPE, p. 4. These files are necessary to compare the Project's maximum daily construction emissions to the SCAQMD's maximum daily thresholds. Id. Reviewing the annual CalEEMod output files., SWAPE determined that the Project's unmitigated construction -related NOx emissions would be 17.83 tons per year. SWAPE, p. 4. Based on this number, SWAPE was able to determine that the Project's would have an average daily emission of 97.7 lbs/day, or just under the 100 lb/day threshold of significance. Id. Since the threshold of significance is based on maximum daily emissions, and the average would be 97.7 lbs/day, SWAPE concludes that there is a fair argument that the Project's maximum daily NOx emissions would exceed the SCAQMD threshold of significance of 100 lbs/day. SWAPE, p. 5. SWAPE's comments constitute substantial evidence supporting a fair argument that the Project will have a significant air quality impact. An EIR is needed to fully analyze and mitigate this potentially significant impact. III. EVEN IF THE 1983 EIR WAS STILL RELEVANT TO THE PROJECT, A SUPPLEMENTAL OR SUBSEQUENT EIR IS NECESSARY BECAUSE SUBSTANTIAL CHANGES WILL RESULT IN NEW AND MORE SIGNIFICANT ENVIRONMENTAL IMPACTS. Even assuming that the 1983 EIR has some relevance to evaluating the environmental impacts of this Project, numerous substantial changes in the development plans have occurred such as the inclusion of 1,900 new residential units, new information of substantial importance has arisen, and substantial changes in circumstances have taken place that require a wholesale revision of the dated 1983 EIR. When changes to a proj ect's circumstances or new substantial information comes to light subsequent to the certification of an EIR for a project, the agency must prepare a subsequent or