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MainPlace Transformation Project City Council Agenda Item 75D June 4, 2019 Page 12 IV. THE ADDENDUM'S CONCLUSIONS ARE NOT SUPPORTED BY SUBSTANTIAL EVIDENCE. A. There is no Evidence that the Project Will Not Result in a New Significant Construction -Related Air Quality Impact. The Addendum concludes that the Project will not have a significant new air quality impact caused by Project construction. This conclusion is not supported by substantial evidence because the Addendum never evaluates the Proj ect's construction -related criteria air pollutant emissions. SWAPE Comments, p. 3. The Addendum's Air Quality Analysis states: The implementation of the improved off -road equipment emissions standards that have occurred since the time of the Final EIR would result in Project construction emissions that are substantially lower than what was anticipated in the Final EIR. The MainPlace Specific Plan also identified sustainability features to enhance sustainability of the Project. These sustainability features include the compliance with all SCAQMD standards for construction equipment and the use of Tier 4 equipment where available during grading. Additionally, construction of the Proposed Project would be required to comply with various SCAQMD rules, including Rule 402 (Nuisance) and Rule 403 (Fugitive Dust). SCAQMD Rules 402 and 403 identify measures to be implemented for the control fugitive dust generated during ground -disturbance activities. As such, construction emissions would be lower than what was anticipated for the Approved Project. No new construction impacts would occur. Addendum, Appendix F, p. 29. The Addendum concludes that the Project's construction -related air emissions would be lower than those anticipated in the 1983 EIR, and therefore the Project would not result in new or more significant impacts. But there is no evidence to support this conclusion. Neither the Addendum nor the 1983 EIR quantified or evaluated the level of criteria air pollutants generated by project construction. Without determining what the actual emissions would be, there is no evidence on which the Addendum can base its conclusion on that the Project will result in lower emissions than the 1983 Project. The South Coast Air Quality Management District ("SCAQMD") is the air pollution control agency for the region in which the Project is located. SWAPE, p. 3. SCAQMD provides quantitative maximum daily significance thresholds significance for emissions of several criteria air pollutants during construction and operational activities. SWAPE, pp. 3-4.