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City of Santa Ana– First American Mixed-Use Project [114 and 117 East Fifth Street] – Comments to City Council November 18, 2019 Page 8 of 13 1. The Addendum Underestimated the Project’s Emissions Mr. Hagemann and Mr. Rosenfeld state that the Addendum used unsubstantiated input parameters to estimate project emissions. Exhibit C, p. 1-2. They explain that the parameters inputted onto CalEEMod.2016.3.2. to calculate the Project’s emissions were incorrect and otherwise inadequate, which results in inaccurate emissions information. First, the Addendum fails to include all proposed land uses and as a result, underestimated the Project’s construction and operational emissions. Exhibit C, p. 2. Specifically, the Addendum failed to include the Project’s inclusion of 332 parking spaces into the CalEEMod emissions calculation, which resulted in the failure to account for the construction and operational emissions associated with such parking spaces. Next, the Addendum underestimated land use sizes by 1,000 feet of the Project’s floor surface area of the strip mall component of the Project. Exhibit C, p. 2. Moreover, the Addendum underestimated Saturday and Sunday trip rates by approximately 59 and 320 trips, which also underestimated the emissions resulting from such trip rates unaccounted for. 2. The Addendum Failed to Adequately Evaluate the Health Risks Associated with the Project’s Diesel Particulate Matter Emissions According to Mr. Hagemann and Mr. Rosenfeld, diesel particulate matter (DPM) health risk emissions was not adequately evaluated in the Addendum. The Addendum incorrectly relied upon a Localized Significance Threshold (LST) analysis, rather than conducting a quantified health risk assessment (HRA). Exhibit C, p. 4. Without a quantified HRA, the Addendum’s conclusion that the Project’s health risk impacts will be less than significant is unsupported. Id. Moreover, the Addendum relies on a flawed CalEEMod model which underestimated the excess cancer risk posed to nearby residents as a result of Project emissions. Exhibit C, p. 4. Finally, according to Mr. Hagemann and Mr. Rosenfeld, the omission of a quantified HRA is inconsistent with the most recent guidance published by the Office of Environmental Health Hazard Assessment (OEHHA), which is the organization responsible for providing guidance on conducting HRAs in California. Exhibit C, p. 6. OEHHA recommends all projects with construction lasting at least 2 months be