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South Coast AOMD Air Ouality Sienificance Thresholds Mass Daily Thresholds Pollutant Construction" Operation' NO, 1001bs/day 551bs/day VOC 75 Ibs/day 55 Ibs/day PMm 150 lbs/day 1501bs/day PMzs 55 Ibs/day 55 Ibs/day SM 150 Ibs/day 150 Ibs/day CO 550 Ibs/clay 550 Ibs/day I,,wd 3 Ibs/day 3 Ibs/day As the above excerpt demonstrates, the SCAQMD provides quantitative thresholds which land use development projects must use to determine the significance of emissions associated with construction and operational activities. Therefore, absent the quantification of construction air pollutant emissions and comparison to applicable thresholds, the 2019 Addendum cannot make any significance conclusions regarding the Project's air quality impacts. Thus, impacts from the Project's construction -related air pollutant emissions must be quantified, compared to thresholds, and additional mitigation should be implemented to the extent necessary. Furthermore, although the 2019 Addendum fails to report the Project's construction air pollutant emissions, the Addendum's GHG Assessment includes a California Emissions Estimator Model Version CalEEMod.2016.3.2 ("CalEEMod")4 air model for the Project's construction GHG emissions. However, the Applicant only provided the annual CalEEMod modeling and failed to include the summer or winter output files. The annual output files calculate emissions as the total tons per year as compared to the summer and winter output files which estimate emissions as the maximum pounds per day. Therefore, the summer or winter output files are necessary to compare the Project's maximum daily construction emissions to the SCAQMD's maximum daily thresholds. Review of the annual CalEEMod output file demonstrates that the Project's unmitigated construction NOx emissions would be approximately 17.83 tons/year (2019 Addendum, pp. 2766).1 Based on the annual output files, we calculated that construction NOx will have an average daily emission of 97.7 Ibs/day.' As a result, there is a fair 4 CaIEEMod website, available at: http://www.agmd.gov/dots/default-source/caleemod/01 user-39-s-guide2016- 3-2 15n ove mber2017.pdf?sfvrsn=4 s The GHG Emissions Assessment incorrectly inputted Tier 4 Final mitigation into the CalEEMod air model for Project construction (2019 Addendum, pp. 2764-2765). The MainPlace Specific Plan simply states that "[gjrading activities will be required to comply with all SCAQMD standards for construction equipment and will also be required to use Tier 4 equipment if it is available' (see: https://www.santa- ana.org/sites/default/files/pb/planning/Final MainPlace SP Online Viewing.pdf, P. 2-22). The MainPlace Specific Plan does not actually require the use of Tier 4 equipment, and thus the 2019 Addendum cannot rely upon this mitigation when modeling emissions. As a result, we rely upon the CalEEMod model's unmitigated emissions, as they more accurately represent the Project's construction emissions. s Calculate: (17.83 tons/year) x (1 year/365 days) x (2000 Ibs/ton) = 97.7 Ibs/day.