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MamPlace Transformation Project City Council Agenda Item 75D June 4, 2019 Page 14 Although the closest sensitive receptors are located approximately 300 feet from the property line of the Project, construction would not occur at the property line, but would be setback approximately 300 feet the property line that is closest to the sensitive receptors... According to the GARB Air Quality and Land Use Handbook (2005), pollutant concentrations drop off drastically with distance (i.e., a 70 percent drop off in pollutant concentrations at 500 feet from the source). Additionally, construction equipment and vehicles in general have become cleaner and release less emissions than when the 1983 EIR was certified and when the 1996 Addendum was adopted. As a result, construction emissions would be lower than what was anticipated in both the 1983 EIR and the 1996 EIR, and no new impacts would occur. Addendum, p. 114. The Addendum concludes that the Project's health risk impact to nearby sensitive receptors 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 evaluated the health risk impact to nearby sensitive receptors. Without determining what the actual health risk will be, there is no evidence on which the Addendum can base its conclusion on that the Project not result in a new or more significant health risk impact compared to the 1983 Project. C. There is no Evidence to Support the Addendum's Conclusion that the Project Will Result in Trip Generation No Worse Than the 1983 Project. The Addendum concludes that the Project will have no new traffic impact compared to the project analyzed in the 1983 EIR. Addendum, p. 70. This conclusion is not supported by substantial evidence because the analysis relies on an inconsistent method of comparing impacts in the 1983 EIR and the Addendum. The Addendum calculates trip generation numbers for the proposed Project + existing baseline and for the full buildout of the project analyzed in the 1983 EIR using the current edition of the Institute of Transportation Engineers Trip Generation 10th Edition, which was released in 2017, as well as current understandings of trip internalization at mixed -use developments and the capture of passerby traffic. Smith Comments, p. 2. In contrast, the original trip generation estimates used to analyze the project's impacts in the 1983 EIR were calculated based on trip rates in the then -current traffic model in use in Santa Ana, which was known as the MMTS/SATC model, and verified by comparison to actual observe hip generation at 8 large office complexes in Southern California. Id. Unlike the Addendum, in the 1983 analysis, no adjustments were made for internalization of trips or passerby attraction. Relying on current trip generation estimates for both the Project and the original 1083 project, the Addendum concludes that the current Project would generate 6,251 fewer daily trips